Section 139(1) of the Income Tax Act

Income-tax Act, 2025: s.263

Section 139(1) falls under section 139 of the Income-tax Act, 1961, which corresponds to section 263 (Return of income) of the Income-tax Act, 2025.

Read section 263 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 139(1) is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 of the 8,117 judgments on BharatTax that turn on this section.

Leading authorities on Section 139(1)

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

CIT v. Pruthvi Brokers & Shareholders
349 ITR 336 · 2012 · High Court
956
citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Union of India v. Azadi Bachao Andolan
263 ITR 706 · 2003 · Supreme Court
691
citing judgments

A citizen is free to carry on business within the law, and mere tax planning without a motive to evade taxes through colorable devices is not frowned upon. The liability to taxation, for the purpose of tax treaty application, is a legal situation, not the fiscal fact of actual payment.

(i) CIT v. Merchem Ltd.
378 ITR 443 · 2015 · High Court
631
citing judgments

Belated remittance of employees' contribution to ESI and PF, even if deposited before the due date for filing the return of income under Section 139(1), is not allowed as a deduction. This disallowance falls under Section 36(1)(va) read with Section 2(24)(x), as Section 43B applies only to employer's contributions.

Co-operative Bank Ltd. v. CIT
384 ITR 490 · 2016 · High Court
631
citing judgments

Co-operative banks are not fundamentally different from co-operative societies, entitling them to claim deductions under Section 80P of the Income Tax Act, 1961, including for interest income treated as business income.

CIT v. Ghatge Patil Transports Ltd.
368 ITR 749 · 2014 · High Court
609
citing judgments

Deduction for employees' contributions to PF and ESIC is allowable under Section 43B if paid before the due date for filing the return under Section 139(1); similarly, delayed deposits of employers' contributions to ESIC and PF are also allowable.

Judgments on Section 139(1)

Azim Kassam Boblai, Mumbai vs. ITO Ward 41(1)(3), Mumbai

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

ITA 4391/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Nov 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Azim Kassam Boblai Vs. Ito, Ward 41(1)(3), A/204, Roshni Mahal, Mumbai Mumbai Puna Road Thane, Kautilya Bhawan, C41- Diwa B.O, Nagaon, Thane, 43, Avenue 3, Near Mumbai- 400612 Videsh Bhavan, G Block Bkc, Gilban Area, Bandra Kurla Complex, Bandra East, Mumbai- 400051 Pan/Gir No. Aetpb414J (Applicant) (Respondent)

Section 139(1)Section 143(2)Section 148Section 250

Infinity Towers Co Op Hsg Soc Ltd, Mumbai vs. ITO 22(1)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 3557/MUM/2025[2022-23]Status: DisposedITAT Mumbai25 Nov 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Neelam Jadhav a/wFor Respondent: Shri Bhagirath Ramawat, (SR.DR.)
Section 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

Infinity Towers Co Operative Housing Society Limited, Mumbai vs. ITO 22(1)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 3556/MUM/2025[2021-22]Status: DisposedITAT Mumbai25 Nov 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Neelam Jadhav a/wFor Respondent: Shri Bhagirath Ramawat, (SR.DR.)
Section 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

Infinity Towers Co Operative Housing Society Limited, Mumbai vs. ITO -22(1)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 3555/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Nov 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Neelam Jadhav a/wFor Respondent: Shri Bhagirath Ramawat, (SR.DR.)
Section 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

Kalyanam Karoti Meerut, Meerut vs. ITO Exemption Gzb, Ghaziabad

Appeal is allowed

ITA 6505/DEL/2025[2017-18]Status: DisposedITAT Delhi25 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Kalyanam Karoti, Vs. Income Tax Officer, 105, First Floor, Cgo Ii, Exemption, Hapur, Chungi, Ghaziabad Ghaziabad Pan: Aaaak2780N (Appellant) (Respondent) Assessee By Sh. Sanjay Malik, Adv. Department By Sh. Manoj Kumar, Sr. Dr

Section 11Section 139(1)

Rajesh Sivan, Ernakulam vs. Income Tax Officer, Ward 1 & Tps, Kannur

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

ITA 688/COCH/2025[2019-20]Status: DisposedITAT Cochin24 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2019-20 Rajesh Sivan .......... Appellant Adhibhavan, Thrikkakara S.O., Ernakulam [Pan: Banps8167A] Vs. The Income Tax Officer, Wd-1 & Tps, Kannur .......... Respondent Assessee By: Shri Lukose Joseph, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 29.10.2025 Date Of Pronouncement: 24.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 18.07.2025 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Engaged In The Business Of Construction Of Residential Houses. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) Was Filed For Ay 2019-20 By The Appellant. Based On The Information That The Appellant Had Made Deposits In Bank Of Baroda & Federal Bank Aggregating To Rs. 39,86,000/- , The Ao Issued A Notice U/S. 148 Of The Act, 1961 (The 2 Rajesh Sivan Act) 29.03.2023. In Response To Notice U/S. 148, The Appellant Filed Return Of Income On 28.04.2023 Declaring Total Income Of Rs. 6,12,020/-. Against The Said Return Of Income, The Assessment Was Completed By The Assessment Unit Of Income Tax Department (Hereinafter Called "The Ao") Vide Order Dated 14.02.2024 Passed U/S. 147 R.W.S. 144B Of The Act At Total Income Of Rs. 45,98,020/-. While Doing So, The Ao Treated The Cash Deposits In The Bank Accounts Of Rs. 39,86,000/- As Unexplained Money Of The Appellant & Brought To Tax The Same.

For Appellant: Shri Lukose Joseph, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148

Francis Liston, Ernakulam vs. Income Tax Officer, Noncorporate Ward 2(1), Kochi, Ernakulam

In the result, the appeal of the assessee bearing ITA No

ITA 673/COCH/2025[2011-12]Status: DisposedITAT Cochin24 Nov 2025AY 2011-12

Bench: Shri Inturi Rama Rao & Shri Anikesh Banerjee

For Appellant: Shri Francis ListonFor Respondent: Smt. Leena Lal. Snr DR
Section 139(1)Section 148Section 24Section 250Section 271(1)(c)Section 274

M. Agathiyan, Thiruvarur vs. ITO, Ward-1, Tiruvarur

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

ITA 2521/CHNY/2025[2020-21]Status: DisposedITAT Chennai24 Nov 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.2521/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Muthuvel Agathiyan, Vs. The Income Tax Officer, 18, Keela Fourth Street, Mannargudi Ward 1, Post, Mannargudi, Thiruvarur 614 001. Thiruvarur. [Pan:Aihpa1940J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Kaarthick, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.11.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.07.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. When The Appeal Was Taken Up For Hearing, The Ld. Ar Shri S. Kaarthick, Advocate Drew Our Attention To Ground No. K Raised In The Grounds Of Appeal & Submits That The Assessee Challenged

For Appellant: Shri S. Kaarthick, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 133(6)Section 135ASection 139(1)Section 147Section 148Section 148A

Usha Mohan, Bangalore vs. Income Tax Officer, Ward-3(2)(1), Bangalore

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

ITA 127/BANG/2025[2015-16]Status: DisposedITAT Bangalore24 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2015-16

For Appellant: Shri Zain Ahmed Khan, CA
Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 54

The Krishna Farmers Service Cooperative Society Limited, Jaggaiahpet vs. Income Tax Officer, Ward -1(3), Vijayawada

In the result, appeal of the assessee is allowed for statistical purposes

ITA 130/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam21 Nov 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 139(1)Section 142(1)Section 144Section 80ASection 80PSection 80P(2)(a)

Valuzhathil Padmanabhan Sivadasan, Thiruvalla vs. Income Tax Officer, Ward-2, Thiruvalla

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

ITA 770/COCH/2025[2015-16]Status: DisposedITAT Cochin21 Nov 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2015-16 Valuzhathil Padmanabhan Sivadasan .......... Appellant Valuzhathil House, Kozhuvalloor, Thiruvalla [Pan: Akaps3606C] Vs. The Income Tax Officer, Ward-2, Thiruvalla .......... Respondent Assessee By: Shri Stephen George, Ar Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-2, Noida [Cit(A)] Dated 25.08.2025 For Assessment Year (Ay) 2015-16. 2. Brief Facts Of The Case Are That The Appellant Is A Non-Resident Indian. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) Was Filed By The Appellant. The Dcit (International Taxation) Lkn (Hereinafter Called "The Ao"), Based On The Information That The Appellant Made Term Deposits In Bank & Earned Interest Income Of Deposits, Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, The 2 Valuzhathil Padmanabhan Sivadasan Ao Issued A Notice U/S. 148 Of The Act After Duly Complying The Provisions Of Section 148(A) Of The Act. In Response To The Notice U/S. 148, The Appellant Filed Return Of Income For Ay 2016-17 On 30.08.2022 Declaring Total Income Of Rs. 2,44,870/-. Against The Said Return Of Income, The Assessment Was Completed By The Ao Vide Order Dated 26.05.2023 Passed U/S. 147 R.W.S. 144C(3) Of The Act At Total Income Of Rs. 35,01,948/-. While Doing So, The Ao Brought To Tax The Income Of Salary Of Rs. 32,57,078/-.

For Appellant: Shri Stephen George, ARFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 4(1)(a)

Jojo, Thrissur vs. ITO Ward-1(1), Thrissur

In the result, the appeal filed by the assessee stands dismissed

ITA 769/COCH/2025[2020-21]Status: DisposedITAT Cochin21 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2020-21 Jojo .......... Appellant Kattalapeedika House, Mattathur, Thrissur [Pan: Bycpj5296A] Vs. The Income Tax Officer, Ward-1(1), Thrissur .......... Respondent Assessee By: Shri Vibin K.K., Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 26.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 29.08.2025 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That Appellant Is An Individual. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) For Ay 2020-21 Was Filed By The Appellant. Based On The Information That The Appellant Had Sold Immovable Property For A Consideration Of Rs. 20,00,000/- The Assessment Unit Of Income Tax Department (Hereinafter Called "The Ao") Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, A Notice U/S. 148 Of The Act Was Issued On 28.03.2024

For Appellant: Shri Vibin K.K., CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 148ASection 54

Shamsudeen Abdul Khadar, Kollam vs. ITO, Ward-2, Kollam

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

ITA 768/COCH/2025[2017-18]Status: DisposedITAT Cochin21 Nov 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Shamsudeen Abdul Khadar .......... Appellant Nusaifa Manzil, Chithara, Madathara Kottarakkara, Kollam 691541 [Pan: Arjpa0218Q] Vs. The Income Tax Officer, Ward-2, Kollam .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 15.07.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. The Appellant Had Not Filed The Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) For Ay 2017-18. Based On The Information That The Appellant Had Deposited Cash Amounting To Rs. 12,07,500/- During Ay 2017-18 In Bank Account Maintained With Kerala Grameen Bank, The Ao Formed An Opinion That Income Escaped Assessment To Tax. Therefore, The Ao

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 68

Puthur Kulangara Jacob Pauly, Thrissur vs. Income Tax Officer, Ward-1(1), Thrissur

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

ITA 754/COCH/2025[2016-17]Status: DisposedITAT Cochin21 Nov 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2016-17 Puthur Kulangara Jacob Pauly .......... Appellant Puthur Kulangara House, Alagappanagar P.O. Mukundapuram, Thrissur 680301 [Pan: Arapp8842J] Vs. The Income Tax Officer, Ward-1, Thrissur .......... Respondent Assessee By: Shri Lokanathan, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 04.06.2025 For Assessment Year (Ay) 2016-17. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) Was Filed By The Appellant For Ay 2016-17. As Per The Information Flagged In Accordance With The Risk Management Strategy Formulate By The Cbdt & Evidence In Possession, The Appellant Had Sold Immovable Property In Ay 2015- 16 For A Consideration Of Rs. 1,14,80,000/-. Accordingly, The 2 Puthur Kulangara Jacob Pauly Assessment Unit Of Income Tax Department (Hereinafter Called "The Ao") Issues A Notice U/S. 148 Of The Act On 06.03.2023. In Response To The Notice U/S. 148, The Appellant Filed Return Of Income On 05.04.2023 Declaring Total Income Of Rs. 12,500/-. Against The Said Return Of Income, The Assessment Was Completed By The Ao Vide Order Dated 28.02.2024 Passed U/S. 147 R.W.S. 144B Of The Act At A Total Income Of Rs. 45,73,680/-. While Doing So, The Ao Made Addition Of Rs. 45,61,180/- On Account Of Short Term Capital Gain.

For Appellant: Shri Lokanathan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 250(6)

Kadukutty Service Co-Operative Bank Ltd - No: 628, Thrissur vs. Ward 1, (1), Thrissur

In the result, the appeal filed by the assessee stands dismissed

ITA 636/COCH/2025[2013-14]Status: DisposedITAT Cochin21 Nov 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2013-14 Kadukutty Service Co-Op. Bank Ltd. .......... Appellant Kadukutty P.O., (Via) Chalakkudy, Thrissur [Pan: Aabak0755A] Vs. The Income Tax Officer, Ward-1(1), Thrissur .......... Respondent Assessee By: Shri Yash, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 18.07.2025 For Assessment Year (Ay) 2013-14. 2. Brief Facts Of The Case Are That The Assessee Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant Had Not Filed Return Of Income For Ay 2013-14 Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act). Based On The Information That The Appellant Had Deposited Cash In The Bank

For Appellant: Shri Yash, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139Section 139(1)Section 142(1)Section 147Section 148Section 80ASection 80A(5)Section 80P

Pawan Kumar Agarwal, Kolkata vs. ITO 22(2), Kolkata

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 964/KOL/2025[2017-18]Status: DisposedITAT Kolkata21 Nov 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 964/Kol/2025 Assessment Year: 2017-2018 Pawan Kumar Agarwal,………….………...……Appellant P-912, Lake Town, Block-A, Kolkata-700089, West Bengal [Pan:Acvpa3110A] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-22(2), Kolkata, Bamboo Villa, Kolkata-700014 Appearances By: Shri Akshay Ringasia, Advocate, Appeared On Behalf Of The Assessee Shri Sanjib Kumar Paul, Addl. Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 19, 2025 Date Of Pronouncing The Order: November 21, 2025 O R D E R

Section 139(1)Section 69A

Mohammad Naushad, Kolkata vs. Income Tax Officer Ward 32(1), Kolkata

In the result, appeal of the assessee is allowed for statistical purposes

ITA 900/KOL/2025[2016-17]Status: DisposedITAT Kolkata21 Nov 2025AY 2016-17

Bench: the Tribunal has arisen. It has also been submitted by the assessee that the delay is neither deliberate nor intention but occurred due to circumstances beyond his control and prayed for condonation of delay. On the other hand, Ld. Sr. DR has also not objected to condone the delay. In view of the above and considering the contention of the assessee stated in the affidavit, the delay of 56 days in filing the present appeal is condoned and the appeal is admitted for hearing.

For Appellant: Shri Ajay Tiwari, CAFor Respondent: Shri Sima Das Biswas, Sr. DR
Section 139(1)Section 44A

Takdah Lingding G P S K U S Limited, Takdah, Darjeeling vs. I.T.O., Ward - 3(3), Darjeeling

In the result, the appeal of the assessee is allowed

ITA 753/KOL/2025[2018-2019]Status: DisposedITAT Kolkata21 Nov 2025AY 2018-2019

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumartakdah Lingding Gpskus Ltd, Vs Ito, Ward-3(3), Darjeeling 1, Takdah, Village-Takdah, Darjeeling, West Bengal-734222 Pan No. : Aadat 6301 M (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Ms. Promita Majumdar, Ar राज"व क" ओर से /Revenue By : Shri S.B.Chakrabrthy, Addl.Cit-Sr.Dr सुनवाई क" तार"ख / Date Of Hearing : 13/10/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/11/2025 आदेश / O R D E R The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Addl/Jcit(A)-4, Chennai, Dated 24.02.2025 Passed For Assessment Year 2018-2019. 2. The Only Issue In The Present Appeal Is With Regard To Disallowance Of Deduction Claimed U/S.80P Of The Act. 3. Ld. Ar Submitted That The Assessee Is A Cooperative Society Registered Under The West Bengal Cooperative Societies Act. The Assessee Had Filed Its Return Of Income For The Impugned Assessment Year On 05.10.2018 Declaring Nill Income & Claimed Deduction U/S.80P Of The Act To An Extent Of Rs.13,58,174/-. It Was The Submission That The Return Of Income Filed By The Assessee Was Processed & Intimation U/S.143(1) Of The Act Was Issued Without Granting The Assessee Benefit Of Deduction U/S.80P Of The Act. Ld. Ar Further Submitted That The Ld. Addl/Jcit(A) Failed To Appreciate That The Due Date Of Filing Of The Return U/S.13(1) Of The Act For 2

For Appellant: Ms. Promita Majumdar, ARFor Respondent: Shri S.B.Chakrabrthy, Addl.CIT-Sr.DR
Section 119Section 13(1)Section 143(1)Section 80PSection 850P

Shri Chatrapati Shivaji Vividoddeshagala Sahakari Sangha Niyamita Haliyal, Haliyal vs. Pr. Commissioner of Income Tax, Hubbali

ITA 1186/BANG/2025[2020-21]Status: DisposedITAT Bangalore21 Nov 2025AY 2020-21

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2020-21 M/S. Shri Chatrapati Shivaji Vividoddeshagala Vs. Pcit, Sahakari Sangha Niyamita, Hubli. Near Mlc Office, Bus Stand Road, Haliyal – 581 329, Karnataka. Pan : Aajas 9684 G Appellant Respondent Assessee By : Shri. Vinay K Kulkarni, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 30.10.2025 Date Of Pronouncement : 21.11.2025

For Appellant: Shri. Vinay K Kulkarni, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 139(1)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

M/S. Reliable Stokists Pvt. Ltd., Kolkata vs. D.C.I.T., CC-2(3), Kolkata

In the result, both the appeals of the assessee are allowed

ITSSA 94/KOL/2025[2013-2014]Status: DisposedITAT Kolkata20 Nov 2025AY 2013-2014

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyit(Ss)A Nos.94&95/Kol/2025 Assessment Years: 2013-14 & 2015-16 M/S Reliable Stokists Pvt. Ltd...……………………….……….……….……Appellant 6A, Ajc Bose Road, Beckbagan, Circus Avenue S.O, Kol- 700017.. [Pan: Aaecr1289F] Vs. Dcit, Central Circle-2(3), Kolkata….…………………….....……...…..…..Respondent Appearances By: Shri Robin Maheshwari & Deepak Mundra, Cas, Appeared On Behalf Of The Appellant. Shri Sanat Kumar Raha, Cit(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 18, 2025 Date Of Pronouncing The Order : November 20, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 09.04.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Since The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. It(Ss)A No.94/Kol/2025 Is Taken As Lead Case.

Section 132(1)Section 139(1)Section 143(1)Section 153ASection 250