Section 80AC of the Income Tax Act

The decision most relied on for Section 80AC is AA520 Veerappampalayam Primary Agricultural Cooperative Credit Society Ltd. v. Deputy Commissioner of Income Tax (138 Taxmann.com 571), cited in 78 of the 666 judgments on BharatTax that turn on this section.

Leading authorities on Section 80AC

AA520 Veerappampalayam Primary Agricultural Cooperative Credit Society Ltd. v. Deputy Commissioner of Income Tax
138 Taxmann.com 571 · 2022 · High Court
78
citing judgments

The Centralized Processing Centre (CPC) can deny deductions claimed under Chapter VI-A, such as Section 80P, during the processing of a return under Section 143(1) if conditions for claiming such deductions, including filing the return by the due date as per Section 80AC, are not met.

Nileshwar Range Kallu Chethu Vyavasaya Thozhilali Sahakarana Sangham v. CIT
459 ITR 730 · 2023 · High Court
76
citing judgments

Timely filing of the income-tax return under section 139(1) is a mandatory condition for claiming deductions under Chapter VI-A, including section 80P, especially for Assessment Years 2018-19 onwards due to the amendment to section 80AC. Such deductions are not allowable if the return is filed belatedly or in response to a section 148 notice.

EBR Enterprises v. Union of India
107 Taxmann.com 220 · 2019 · High Court
69
citing judgments

Deductions under Chapter VI-A (e.g., Sections 10B, 10BA) and other specified provisions are not allowable if the claim is not explicitly made in the return of income as mandated by Section 80A(5). Such a claim cannot be subsequently entertained during assessment proceedings or even during revision proceedings under Section 264.

Chirakkal Service Co-Operative Bank Ltd. Kannur v. CIT
68 Taxmann.com 298 · 2016 · High Court
62
citing judgments

A deduction under Section 80P can be claimed by an assessee even if the return of income is filed belatedly under Section 139(4), provided a return has been filed.

Chirakkal Service Co- Operative Bank Ltd. v. CIT
111 Taxmann.com 49 · 2019 · Reported
45
citing judgments

An adjustment under section 143(1)(a)(ii) or (v) of the Income-tax Act cannot be made without affording the assessee an opportunity to explain their case, as considerations like Section 80AC(ii) do not fall within the scope of adjustments permissible at the section 143(1) stage.

Lanjani Co-Operative Agri Service Society Ltd. (CPC) v. DCIT
146 Taxmann.com 468 · 2023 · ITAT
33
citing judgments

Adjustments under section 143(1)(a)(ii) cannot be made if the assessee's case is allowable on facts. The Assessing Officer or CPC cannot exercise powers under section 143(1) to make adjustments contrary to the facts allowable to the assessee, even when considering amended sections like 80AC.

Ultratech Cement Ltd. v. Additional Commissioner of Income Tax
408 ITR 500 · 2018 · High Court
32
citing judgments

A tribunal can exercise its discretion to admit an additional ground of appeal, even if raised for the first time, provided it considers the facts and circumstances of the case.

Nileshwar Rangekallu Chethu Vyavasaya Thozhilali Sahakarana Sangham v. CIT
152 Taxmann.com 347 · 2023 · High Court
31
citing judgments

A claim for deduction under section 80P must be made in a valid return filed within the timelines prescribed by the Act (prior to April 1, 2018, this included sections 139(1), 139(4), 142(1), or 148; post-amendment, only section 139(1) is accepted). Statutory benefits like this deduction require strict adherence to legal conditions.

Gopal and Sons (HUF) v. Commissioner of Income-tax, Kolkata-XI
77 Taxmann.com 71 · 2017 · Supreme Court
31
citing judgments

Section 2(22)(e) of the Income Tax Act applies if a shareholder has a substantial interest in a company that receives a loan, making the loan amount a deemed dividend.

CIT v. Impact Containers Pvt. Ltd.
367 ITR 346 · 2014 · High Court
27
citing judgments

Section 2(22)(e) cannot be applied where the assessee is not a shareholder of the lending company, as its purpose is to prevent tax avoidance by distributing company profits as loans to shareholders.

Judgments on Section 80AC

S 224 Kattanachampatty Primary Agricultural Co-Op Credit Society, Namakkal vs. ITO, Namakkal

ITA 2323/CHNY/2026[2017-18]Status: DisposedITAT Chennai23 Jun 2026AY 2017-18

Bench: Honourable Shri Aby T. Varkey & Shri Gagan Goyalआयकर अपील सं./Ita No. 2323/Chny/2026 ननिाारण वर्ा /Assessment Years: 2017-18 S 244 Kattanachampatty Primary V. The Income Tax Officer, Agricultural Co-Op. Credit Society, Ward –2 No.67C/3 Vallalar Kovil Backside, Namakkal. Kattukottai, Rasipuram Taluk, Namakkal, Tamil Nadu-637 408. [Pan: Ablas8536L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. T. Vasudevan, Advocate, Ld. Ar प्रत्यर्थी की ओर से /Revenue By : Mr.Chilaka Marthi Vijay Raju, Addl. Cit, Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18.06.2026 घोषणाकीतारीख /Date Of Pronouncement : 23.06.2026 आदेश / O R D E R Per Gagan Goyal, Am: This Is An Appeal Preferred By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (A) / Nfac, (Hereinafter Referred As The ‘Ld. Cit(A)’) Dated 06.01.2026, For The Assessment Year (Hereinafter Referred As The ‘Ay’) 2017-18. Grounds Of Appeal 1. The Order Of The Cit (A) / Nfac In Dismissing The Appeal In Limine Is Contrary To Law, Erroneous & Unsustainable On The Facts Of Case. 2. The Ld. Cit (A) / Nfac Erred In Not Condoning The Delay Of 184 Days In Filing The Appeal, Although The Assessee Had Explained In The Petition The Reason For The Delay.

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Mr.Chilaka Marthi Vijay Raju
Section 139Section 148Section 69ASection 80P

Tyspl 109 V Kalathur Primary Agricultural Co-Op, Perambalur vs. ITO, Perambalur

ITA 2298/CHNY/2026[2019-20]Status: DisposedITAT Chennai23 Jun 2026AY 2019-20

Bench: Honourable Shri Aby T. Varkey & Shri Gagan Goyalआयकर अपील सं./Ita No. 2298/Chny/2026 ननिाारण वर्ा /Assessment Years: 2019-20 Tyspl 109 V Kalathur Primary V. The Income Tax Officer, Agricultural Cooperative Credit Society Ward-1, Limited, Perambalur. V Kalathur Post, Perambalur, Tamil Nadu-621 117. [Pan: Aacat5790P] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. T. Vasudevan, Advocate, Ld. Ar प्रत्यर्थी की ओर से /Revenue By : Mr. Chilaka Marthi Vijay Raju, Addl. Cit, Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18.06.2026 घोषणाकीतारीख /Date Of Pronouncement : 23.06.2026 आदेश / O R D E R Per Gagan Goyal, Am: This Is An Appeal Preferred By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (A) / Nfac, (Hereinafter Referred As The ‘Ld. Cit(A)’) Dated 21.03.2026, For The Assessment Year (Hereinafter Referred As The ‘Ay’) 2019-20. Grounds Of Appeal 1. The Order Of The Commissioner Of Income Tax (Appeals) Dismissing The Appeal Is Contrary To Law, Erroneous & Unsustainable On The Facts Of The Case. 2. The Cit (A) Nfac Erred In Upholding The Order Of The Department On Jurisdiction & Merits Of The Case.

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Mr. Chilaka Marthi Vijay Raju
Section 119(2)Section 139Section 139(1)Section 148Section 80P