THE IKKARAIBOLUVAMPATTI PACCS 33,COIMBATORE vs. ITO,NCW 4(2), COIMBATORE

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.461/Chny/2021 िनधा"रण वष" /Assessment Year: 2017-18 M/S.Ikkaraiboluvampatti Paccs, V. The Income Tax Officer, 33, Rajaji Street, Non-Corporate Ward-4(2), Coimbatore. Coimbatore. [Pan: Aaaai 3699 A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.J.Saravanan, Adv. ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 19.10.2022 घोषणा क" तारीख /Date Of Pronouncement : 02.11.2022

E R PER G. MANJUNATHA, AM: This appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 15.09.2021 and pertains to assessment year 2017-18. 2. The brief facts of the case are that the assessee is a primary agricultural credit Co-operative Society registered under Tamil

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

E R PER ABY T. VARKEY, JM: These are appeals preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as “the Ld.CIT(A)”), Delhi, dated 24.09.2025 for the Assessment Year (hereinafter referred to as "AY”) 2016-17, 2017-18, 2018-19 & 2020-21 respectively. Both the parties agreed that

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

E R PER ABY T. VARKEY, JM: These are appeals preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as “the Ld.CIT(A)”), Delhi, dated 24.09.2025 for the Assessment Year (hereinafter referred to as "AY”) 2016-17, 2017-18, 2018-19 & 2020-21 respectively. Both the parties agreed that

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

E R PER ABY T. VARKEY, JM: These are appeals preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as “the Ld.CIT(A)”), Delhi, dated 24.09.2025 for the Assessment Year (hereinafter referred to as "AY”) 2016-17, 2017-18, 2018-19 & 2020-21 respectively. Both the parties agreed that

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

E R PER ABY T. VARKEY, JM: These are appeals preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as “the Ld.CIT(A)”), Delhi, dated 24.09.2025 for the Assessment Year (hereinafter referred to as "AY”) 2016-17, 2017-18, 2018-19 & 2020-21 respectively. Both the parties agreed that

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’).

E R PER GEORGE GEORGE K, VICE PRESIDENT: 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 and dated 10.12.2024 for the assessment year

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’).

E R PER GEORGE GEORGE K, VICE PRESIDENT: 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 and dated 10.12.2024 for the assessment year

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’).

E R PER GEORGE GEORGE K, VICE PRESIDENT: 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 and dated 10.12.2024 for the assessment year

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’).

E R PER GEORGE GEORGE K, VICE PRESIDENT: 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 and dated 10.12.2024 for the assessment year

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’).

E R PER GEORGE GEORGE K, VICE PRESIDENT: 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 and dated 10.12.2024 for the assessment year

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’).

E R PER GEORGE GEORGE K, VICE PRESIDENT: 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 and dated 10.12.2024 for the assessment year

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)

disallowing the deduction claimed under Section 80P(2)(a)(i). Furnishing of Return of Income - Section 139(4) 3) The CIT(A) failed to see that the assessee had furnished his return of income within the time frame prescribed under section 139(4) of the Income Tax Act, 1961. Circular No. 13/2023 allows condonation of delay for deduction u/s 80P

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)

disallowing the deduction claimed under Section 80P(2)(a)(i). Furnishing of Return of Income - Section 139(4) 3) The CIT(A) failed to see that the assessee had furnished his return of income within the time frame prescribed under section 139(4) of the Income Tax Act, 1961. Circular No. 13/2023 allows condonation of delay for deduction u/s 80P

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

disallowing the deduction claimed u/s. 80P. Both the Assessing Officer and the CIT(A) failed to appreciate that the relevant interest and dividend are deductible not only u/s 8OP(2)(a)(i) but also uls 80P(2)(d). 4. The Ld. Assessing Officer and the CIT(A) failed to appreciate that the Chennai Central Cooperative Bank is a Co-Operative

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)(d). 4. Without prejudice, the Learned Commissioner (Appeals) erred in not following the decision of the jurisdictional High Court in TCA No. 5 of 2015 dated 10/08/2016 and the decision reported in [2023] 156 taxmann.com 419 (Madras), the copies of which were also submitted by the Appellant Society in its reply dated 25/12/2023 vide

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)(d). 4. Without prejudice, the Learned Commissioner (Appeals) erred in not following the decision of the jurisdictional High Court in TCA No. 5 of 2015 dated 10/08/2016 and the decision reported in [2023] 156 taxmann.com 419 (Madras), the copies of which were also submitted by the Appellant Society in its reply dated 25/12/2023 vide

K274 UTHUKULI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD,TIRUPUR vs. ITO , NFAC , DELHI

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.: 860/Chny/2022 िनधा"रण वष" / Assessment Year: 2018-19

E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: This appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 25.08.2022 and pertains to assessment year 2018-19. :-2-: ITA. No: 860/Chny/2022 2. The assessee has raised the following grounds of appeal

THE THANJAVUR DISTRICT CO OP MILK PRODUCERS UNION LIMITED,THANJAVUR vs. ACIT, CIRCLE2(1), TRICHY

In the result, appeal of the Assessee is Allowed

Bench: Shri Mahavir Singh, Vice- & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.404/Chny/2022 िनधा"रणवष" / Assessment Year : 2017-18 The Thanjavur District Co Op The Principal Milk Producers Union Limited, Vs Commissioner Of Income No.1, Nanjikottai Road, Tax-1, Madurai. Thanjavur – 613006. Pan: Aaaat 0224 E Appellant/ Assessee Respondent /Revenue Assessee By K.Meenakshisundaram - Itp Revenue By Shri M.Rajan – Cit(Dr) Date Of Hearing 23/08/2022 Date Of Pronouncement 21/11/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Appellant Assessee Against The Order U/S 263 Of The Income Tax Act (Act) Of The Principal Commissioner Of Income Tax Madurai-1, Dated 26/03/2022 For A.Y. 2017-18. The Assessee Has Raised Following Grounds Of Appeal: “The Order Under Section 263 Of The Income Tax Act Dated 26/3/2022 Received By The Appellant On 1/4/2022 Is Objected To On The Following Grounds Of Appeal. 1. The Learned Principal Commissioner Madurai Erred In Setting Aside The Valid Order Passed By The Assisstant Commissioner Of Income Tax Circle-2(1) Trichy Dated 5/11/2019 For The Assessment Year 2017- 2018 Under Section 263 On Mere Assumptions & Presumptions That The Order Had Been Erroneous & Prejudicial To The Interest Of Revenue. 2. The Learned Principal Commissioner Misdirected Himself That The Valid Order Passed By The Assisstant Commissioner Was Erroneous & Prejudicial To The Interest Of Revenue Simply For The Reason That The

e), u/s.80P(c) and assessed the income of the assessee at NIL. 2.4 However, the Pr.Commissioner of Income Tax, Madurai- 1(PCIT), issued notice u/s 263 of the Act to the assessee and after giving opportunity to the assessee, passed the order u/s 263 of the Act on 26/03/2022. Assessee has filed appeal before this Tribunal against the said order

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

disallowance of deduction claimed under section 80P(2)(e) of the Act since the assessee has failed to offer any explanation