PERURCHETTIPALAYAM PACCS,COIMBATORE vs. ITO, NCW-4(2), COIMBATORE

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

disallowed the deduction and therefore the present writ petitions have been filed challenging the impugned orders. 4.Per contra, Dr.B.Ramaswamy, learned Senior Central Government Standing Counsel, vehemently opposed and referring to the written submissions submitted by him in paragraphs 21 to 26, would state that the petitioner received the income from the Co-operative Bank and as per the provisions

PERURCHETTIPALAYAM PACCS,COIMBATORE vs. ITO, NCW-4(2), COIMBATORE

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

disallowed the deduction and therefore the present writ petitions have been filed challenging the impugned orders. 4.Per contra, Dr.B.Ramaswamy, learned Senior Central Government Standing Counsel, vehemently opposed and referring to the written submissions submitted by him in paragraphs 21 to 26, would state that the petitioner received the income from the Co-operative Bank and as per the provisions

THE CENTRAL GOVERNMENT STAFF COOPERATIVE THRIFT & CREDIT SOCIETY LIMITED,CHENNAI vs. INCOME TAX OFFICER, NATIONAL E-ASSESSMENT CENTRE,DELHI, DELHI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George George Kand Shri S.R. Raghunathaआयकरअपीलसं/.Ita Nos.:269, 270, 271, 272, 273 & 274/Chny/2025 िनधा"रणवष"/Assessment Years: 2012-13, 2013-14, 2016-17& 2017-18, 2018-19 & 2020-21 The Central Government Staff Income Tax Officer, Cooperative Thrift & Credit Society Vs. Non-Corporate Ward-3(5), Limited, No. 4, Noor Veerasamy Street, Chennai. Nungambakkam, Chennai 600 034. [Pan: Aabat-8783-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri R. Ganesan, C.A. ""यथ"क"ओरसे/Respondent By : Shri A. Sasikumar, Cit सुनवाईक"तारीख/Date Of Hearing : 19.03.2025 घोषणाक"तारीख/Date Of Pronouncement : 20.03.2025 आदेश/ O R D E R Per George George K: These Six Appeals Filed At The Instance Of The Assessee Are Directed Against Six Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 11.12.2024 For The Assessment Years 2012-13, 2013-14, 2017-18, 2018-19 & 2020-21 & Dated 10.12.2024 For The Assessment Year 2016-17, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’).

disallowed the deduction claimed under section 80P(2)(d) of the Act and added to the total income of the assessee. ITA Nos.296 to 299/Chny/2025 5. Aggrieved by the assessment order, the assessee carried the matter in appeal before the ld. CIT(A) and filed detailed written submissions. In its reply, the assessee relied upon the decision of the Coordinate

THE CENTRAL GOVERNMENT STAFF COOPERATIVE THRIFT & CREDIT SOCIETY LIMITED,CHENNAI vs. INCOME TAX OFFICER, NON CORP. WARD 3(5) CHE, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George George Kand Shri S.R. Raghunathaआयकरअपीलसं/.Ita Nos.:269, 270, 271, 272, 273 & 274/Chny/2025 िनधा"रणवष"/Assessment Years: 2012-13, 2013-14, 2016-17& 2017-18, 2018-19 & 2020-21 The Central Government Staff Income Tax Officer, Cooperative Thrift & Credit Society Vs. Non-Corporate Ward-3(5), Limited, No. 4, Noor Veerasamy Street, Chennai. Nungambakkam, Chennai 600 034. [Pan: Aabat-8783-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri R. Ganesan, C.A. ""यथ"क"ओरसे/Respondent By : Shri A. Sasikumar, Cit सुनवाईक"तारीख/Date Of Hearing : 19.03.2025 घोषणाक"तारीख/Date Of Pronouncement : 20.03.2025 आदेश/ O R D E R Per George George K: These Six Appeals Filed At The Instance Of The Assessee Are Directed Against Six Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 11.12.2024 For The Assessment Years 2012-13, 2013-14, 2017-18, 2018-19 & 2020-21 & Dated 10.12.2024 For The Assessment Year 2016-17, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’).

disallowed the deduction claimed under section 80P(2)(d) of the Act and added to the total income of the assessee. ITA Nos.296 to 299/Chny/2025 5. Aggrieved by the assessment order, the assessee carried the matter in appeal before the ld. CIT(A) and filed detailed written submissions. In its reply, the assessee relied upon the decision of the Coordinate

THE CENTRAL GOVERNMENT STAFF COOPERATIVE THRIFT & CREDIT SOCIETY LIMITED,CHENNAI vs. INCOME TAX OFFICER, NON CORP. WARD 3(5) CHE, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George George Kand Shri S.R. Raghunathaआयकरअपीलसं/.Ita Nos.:269, 270, 271, 272, 273 & 274/Chny/2025 िनधा"रणवष"/Assessment Years: 2012-13, 2013-14, 2016-17& 2017-18, 2018-19 & 2020-21 The Central Government Staff Income Tax Officer, Cooperative Thrift & Credit Society Vs. Non-Corporate Ward-3(5), Limited, No. 4, Noor Veerasamy Street, Chennai. Nungambakkam, Chennai 600 034. [Pan: Aabat-8783-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri R. Ganesan, C.A. ""यथ"क"ओरसे/Respondent By : Shri A. Sasikumar, Cit सुनवाईक"तारीख/Date Of Hearing : 19.03.2025 घोषणाक"तारीख/Date Of Pronouncement : 20.03.2025 आदेश/ O R D E R Per George George K: These Six Appeals Filed At The Instance Of The Assessee Are Directed Against Six Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 11.12.2024 For The Assessment Years 2012-13, 2013-14, 2017-18, 2018-19 & 2020-21 & Dated 10.12.2024 For The Assessment Year 2016-17, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’).

disallowed the deduction claimed under section 80P(2)(d) of the Act and added to the total income of the assessee. ITA Nos.296 to 299/Chny/2025 5. Aggrieved by the assessment order, the assessee carried the matter in appeal before the ld. CIT(A) and filed detailed written submissions. In its reply, the assessee relied upon the decision of the Coordinate

THE CENTRAL GOVERNMENT STAFF COOPERATIVE THRIFT & CREDIT SOCIETY LIMITED,CHENNAI vs. INCOME TAX OFFICER, NATIONAL E-ASSESSMENT CENTRE, DELHI, DELHI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George George Kand Shri S.R. Raghunathaआयकरअपीलसं/.Ita Nos.:269, 270, 271, 272, 273 & 274/Chny/2025 िनधा"रणवष"/Assessment Years: 2012-13, 2013-14, 2016-17& 2017-18, 2018-19 & 2020-21 The Central Government Staff Income Tax Officer, Cooperative Thrift & Credit Society Vs. Non-Corporate Ward-3(5), Limited, No. 4, Noor Veerasamy Street, Chennai. Nungambakkam, Chennai 600 034. [Pan: Aabat-8783-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri R. Ganesan, C.A. ""यथ"क"ओरसे/Respondent By : Shri A. Sasikumar, Cit सुनवाईक"तारीख/Date Of Hearing : 19.03.2025 घोषणाक"तारीख/Date Of Pronouncement : 20.03.2025 आदेश/ O R D E R Per George George K: These Six Appeals Filed At The Instance Of The Assessee Are Directed Against Six Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 11.12.2024 For The Assessment Years 2012-13, 2013-14, 2017-18, 2018-19 & 2020-21 & Dated 10.12.2024 For The Assessment Year 2016-17, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’).

disallowed the deduction claimed under section 80P(2)(d) of the Act and added to the total income of the assessee. ITA Nos.296 to 299/Chny/2025 5. Aggrieved by the assessment order, the assessee carried the matter in appeal before the ld. CIT(A) and filed detailed written submissions. In its reply, the assessee relied upon the decision of the Coordinate

THE CENTRAL GOVERNMENT STAFF COOPERATIVE THRIFT & CREDIT SOCIETY LIMITED,CHENNAI vs. INCOME TAX OFFICER, NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, DELHI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George George Kand Shri S.R. Raghunathaआयकरअपीलसं/.Ita Nos.:269, 270, 271, 272, 273 & 274/Chny/2025 िनधा"रणवष"/Assessment Years: 2012-13, 2013-14, 2016-17& 2017-18, 2018-19 & 2020-21 The Central Government Staff Income Tax Officer, Cooperative Thrift & Credit Society Vs. Non-Corporate Ward-3(5), Limited, No. 4, Noor Veerasamy Street, Chennai. Nungambakkam, Chennai 600 034. [Pan: Aabat-8783-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri R. Ganesan, C.A. ""यथ"क"ओरसे/Respondent By : Shri A. Sasikumar, Cit सुनवाईक"तारीख/Date Of Hearing : 19.03.2025 घोषणाक"तारीख/Date Of Pronouncement : 20.03.2025 आदेश/ O R D E R Per George George K: These Six Appeals Filed At The Instance Of The Assessee Are Directed Against Six Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 11.12.2024 For The Assessment Years 2012-13, 2013-14, 2017-18, 2018-19 & 2020-21 & Dated 10.12.2024 For The Assessment Year 2016-17, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’).

disallowed the deduction claimed under section 80P(2)(d) of the Act and added to the total income of the assessee. ITA Nos.296 to 299/Chny/2025 5. Aggrieved by the assessment order, the assessee carried the matter in appeal before the ld. CIT(A) and filed detailed written submissions. In its reply, the assessee relied upon the decision of the Coordinate

THE CENTRAL GOVERNMENT STAFF COOPERATIVE THRIFT & CREDIT SOCIETY LIMITED,CHENNAI vs. INCOME TAX OFFICER, NON CORP. WARD 3(5) CHE, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George George Kand Shri S.R. Raghunathaआयकरअपीलसं/.Ita Nos.:269, 270, 271, 272, 273 & 274/Chny/2025 िनधा"रणवष"/Assessment Years: 2012-13, 2013-14, 2016-17& 2017-18, 2018-19 & 2020-21 The Central Government Staff Income Tax Officer, Cooperative Thrift & Credit Society Vs. Non-Corporate Ward-3(5), Limited, No. 4, Noor Veerasamy Street, Chennai. Nungambakkam, Chennai 600 034. [Pan: Aabat-8783-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri R. Ganesan, C.A. ""यथ"क"ओरसे/Respondent By : Shri A. Sasikumar, Cit सुनवाईक"तारीख/Date Of Hearing : 19.03.2025 घोषणाक"तारीख/Date Of Pronouncement : 20.03.2025 आदेश/ O R D E R Per George George K: These Six Appeals Filed At The Instance Of The Assessee Are Directed Against Six Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 11.12.2024 For The Assessment Years 2012-13, 2013-14, 2017-18, 2018-19 & 2020-21 & Dated 10.12.2024 For The Assessment Year 2016-17, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’).

disallowed the deduction claimed under section 80P(2)(d) of the Act and added to the total income of the assessee. ITA Nos.296 to 299/Chny/2025 5. Aggrieved by the assessment order, the assessee carried the matter in appeal before the ld. CIT(A) and filed detailed written submissions. In its reply, the assessee relied upon the decision of the Coordinate

INCOME TAX OFFICER, WANAPARTHY BLOCK vs. TAMILNADU SPECIAL POLICE EMPLOYEES COOPERATIVE, TSP CAMP

In the result the appeal of the revenue is dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:363/Chny/2025 िनधा"रण वष" / Assessment Year: 2020-21 Income Tax Officer, Tamilnadu Special Police Non-Corporate Ward -7(3), Vs. Employees Cooperative, Chennai – 600 034. Avadi, Chennai – 600 054. [Pan:Aafat-0366-E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Sita Krishnamoorthy, J.C.I.T. ""थ" की ओर से/Respondent By : Shri. G. Reddi Prakash, C.A. सुनवाई की तारीख/Date Of Hearing : 12.06.2025 घोषणा की तारीख/Date Of Pronouncement : 15.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am: This Appeal By The Revenue Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2020-21, Dated 11.10.2024. 2. At The Outset, We Find That There Is A Delay Of 34 Days In Appeal Filed By The Revenue, For Which Petition For Condonation Of Delay Along With Reasons For Delay Has Been Filed. After Considering The Petition Filed By The Revenue & Also Hearing Both The Parties, We Find That There Is A Reasonable Cause For The Revenue In Not Filing Appeal On Or Before The Due Date Prescribed Under The Law & Thus

C. Green Cooperative Housing and Society Ltd. Vs. ITO21(3)(2), Mumbai (ITA No. 1343/Mum/2017, dated 31.03.2017 vii. Marvwanjee Cama Park Cooperative Housing Society Ltd. Vs. ITO-Range- 20(2)(2), Mumbai (ITA No. 6139/Mum/2014, dated 27.09.2017. 4. However, the Assessing Officer was not convinced with the reply filed by the assessee and disallowed the claim of interest and dividend

THE ERODE CITY MUNICIPAL CORPORATION EMP CO-OP T& C LIMITED,ERODE vs. ITO, WARD 1(1), ERODE

In the result, the appeal in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.509 & 510/Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021)

2)(d).] 6.2 Grounds no. A and B are against not being allowed to claim deduction u/s 80P as the return of income was filed beyond the due date specified u/s 139(1). The AO invoked the provisions of section 80AC, as amended w.e.f. 1/4/2018 to deny claim of deduction u/s 80P of Rs. 87,07,378/- The appellant

THE ERODE CITY MUNICIPAL CORPORATION EMP CO-OP T& C LIMITED,CHENNAI vs. ITO, WARD 1 (1), ERODE

In the result, the appeal in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.509 & 510/Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021)

2)(d).] 6.2 Grounds no. A and B are against not being allowed to claim deduction u/s 80P as the return of income was filed beyond the due date specified u/s 139(1). The AO invoked the provisions of section 80AC, as amended w.e.f. 1/4/2018 to deny claim of deduction u/s 80P of Rs. 87,07,378/- The appellant

K 720 T GANAPATHIPALAYAM PACS LIMITED,ERODE vs. ITO WARD 2(1), ERODE

In the result, the appeal filed by the assessee is allowed

section 80P(2)(d) of the Act. The Ld. CIT(A) has\ndismissed the appeal of assessee holding that interest earned from the\nCo-operative bank is neither allowable u/s 80P(2)(a)(i) or 80P(2)(d)\n5. The Ld. Counsel for the assessee has argued that the issue is\nsquarely covered by the Hon'ble Madras High Court

K1104 ELAAMUTHUR PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SCOIETY,TIRUPPUR vs. ITO, WARD 2(4), TIRUPPUR

In the result, appeals filed by the assessee for both the

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita Nos.: 1040 & 1041/Chny/2024 िनधा"रणवष" / Assessment Years: 2016-17 & 2017-18 K 1104 Elayamuthur Primary Income Tax Officer, Agricultural Co-Operative Credit V. Ward -2(4), Society, Tirupur. Elayamuthur, Udumalpet, Tirupur – 642 154. [Pan: Aabak-3636-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S. Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Shri. R.V. Aroonprasaad, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 23.07.2024 घोषणाकीतारीख/Date Of Pronouncement : 18.09.2024

section 80P(2)(i)(a) is disallowed and the entire business profit of Rs. 28,48,881, is taxed under the head, "Business Income" 12. After examining the materials available on record, assessment is completed by disallowing the entire claim of deduction under Chapter VIA as under: For AY 2016-17 Returned Income Nil Add: Business Income

K1104 ELAYAMUTHUR PROMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY,TIRUPPUR vs. ITO, WARD 2(4), TIRUPPUR

In the result, appeals filed by the assessee for both the

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita Nos.: 1040 & 1041/Chny/2024 िनधा"रणवष" / Assessment Years: 2016-17 & 2017-18 K 1104 Elayamuthur Primary Income Tax Officer, Agricultural Co-Operative Credit V. Ward -2(4), Society, Tirupur. Elayamuthur, Udumalpet, Tirupur – 642 154. [Pan: Aabak-3636-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S. Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Shri. R.V. Aroonprasaad, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 23.07.2024 घोषणाकीतारीख/Date Of Pronouncement : 18.09.2024

section 80P(2)(i)(a) is disallowed and the entire business profit of Rs. 28,48,881, is taxed under the head, "Business Income" 12. After examining the materials available on record, assessment is completed by disallowing the entire claim of deduction under Chapter VIA as under: For AY 2016-17 Returned Income Nil Add: Business Income

INCOME TAX OFFICER, CHENNAI vs. RAILWAY EMPLOYEES COOPERATIVE CREDIT SOCIETY, CHENNAI

In the result, the both the appeals filed by the Revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

C’ BENCH, CHENNAI "ी मनु कुमार "ग"र, "या"यक सद"य एवं "ी एस. आर. रघुनाथा, लेखा सद"य के सम# BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.:2095 & 2096/Chny/2025 "नधा$रण वष$ / Assessment Years: 2017-18 & 2018-19 ITO, Railway Employees Co-operative Non-Corporate Ward

INCOME TAX OFFICER, CHENNAI vs. RAILWAY EMPLOYEES COOPERATIVE CREDIT SOCIETY LIMITED, CHENNAI

In the result, the both the appeals filed by the Revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

C’ BENCH, CHENNAI "ी मनु कुमार "ग"र, "या"यक सद"य एवं "ी एस. आर. रघुनाथा, लेखा सद"य के सम# BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.:2095 & 2096/Chny/2025 "नधा$रण वष$ / Assessment Years: 2017-18 & 2018-19 ITO, Railway Employees Co-operative Non-Corporate Ward

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. M/S. LARSEN & TOUBRO GROUP EMPLOYEES CO-OP THRIFT & CREDIT SOCIETY LIMITED, CHENNAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

C' Bench, Bangalore, whereby the learned Tribunal has dismissed six appeals filed by the Revenue against the respondent- assessee. 2. Briefly the facts of the case are that the respondent assessee is a Co-operative Credit Society providing credit facilities to its members, and marketing the agricultural produce of its members; it runs a kirana section, rice mills, van section

THE LALGUDI SIVAGNANAM AGRICULTURAL PRODUCERS CO-OP. MKG SOCIETY LIMITED ,TRICHY vs. DCIT , CIRCLE -1 (1) , TRICHY

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.948/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Lalgudi Sivagnanam Agricultural Vs. The Deputy Commissioner Of Producers Mkg Society Ltd., Income Tax, 171, Lalgudi, Tiruchirapalli 621 601. Circle 1(1), Trichy. [Pan:Aaaat0204A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate [Erode] ""थ" की ओर से/Respondent By : Shri S. Chandrasekaran, Jcit सुनवाई की तारीख/ Date Of Hearing : 10.05.2023 घोषणा की तारीख /Date Of Pronouncement : 17.05.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, Dated 21.09.2022 Relevant To The Assessment Year 2017-18. The Assessee Has Raised The Following Grounds: 1) The Order Of The Learned Cit(A) Is Bad & Erroneous In Law & Against The Principles Of Natural Justice. 2) The Learned Cit(A) Erred In Not Considering The Written Submissions Filed By The Appellant In Proper Perspective. 3) The Learned Cit(A) Erred In Not Considering The Vital & Material Fact That Out Of The Denial Deduction U/S.80P(2)(E), Rs.2,38,907/- Pertains To 2

section 80P of the Act of ₹.92,87,865/- [(80P(2)(a)(i) of ₹.82,89,210 + 80P(2)(c) of ₹.1,00,000 and 80P(2)(d) of ₹.8,98,655], the ld. CIT(A) confirmed the addition of ₹.22,45,302/- towards disallowance