Section 80P(2)(a)(iv) of the Income Tax Act

The decision most relied on for Section 80P(2)(a)(iv) is 411/225 Taxman 6 (Mag.) (Raj.) and CIT v. Jaipur Vidhut Vitaran Nigam Ltd. (363 ITR 307), cited in 115 of the 26 judgments on BharatTax that turn on this section.

Leading authorities on Section 80P(2)(a)(iv)

Judgments on Section 80P(2)(a)(iv)

SHREE CHALALA VI KA SEVA SAHAKARI MANDALI LTD. ,AMRELI vs. THE ITO WARD 3(1)(4), RAJKOT-AMRELI., RAJKOT

The appeal of the assessee is allowed

ITA 358/RJT/2025[2019-20]Status: DisposedITAT Rajkot17 Nov 2025AY 2019-20

Bench: Dr. Arjun Lal Saini, A Ccountant Member & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 358/Rjt/2025 िनधा"रण वष" / Assessment Year: (2019-20) Shree Chalala Vi Ka Seva Sahakari Vs. The Ito Ward 3(1)(4), Mandali Ltd. Aayakar Bhavan, Race Course Ring Chalala Haveli Road, Road, Dhari Amreli - 365630 Rajkot - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatas2273D (Appellant) (Respondent) Appellant By : Ms. Devina Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 27/08/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm; Captioned Appeal Filed By Assessee Pertaining To Assessment Year 2019-20, Is Directed Against Order Passed Under Section 250 Of The Income Tax Act, 1961 By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income Tax (Appeals), Dated 31/03/2025, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(1) Of The Act. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: - 1. The Learned Addl/Jcit (A)-1, Kolkata Erred In Confirming Action Of Cpc, Bangalore In Disallowing Claim Of Deduction Of Rs. 3,51,828/- U/S Sop Of The Act By Failing To Appreciate That Provisions Of Sec. 143(1)(A)(V) Do Not Provide For Denial Of Deduction U/S 80P Of The Act When The Return Of Income Is Not Filed Within Time Allowed U/S 139(1) Of The Act But U/S 139(4). 2. The Learned Addl/Jcit (A)-1, Kolkata Erred In Upholding Action Of The Cpc, Bangalore In Making Adjustment To The Returned Income Of The Appellant By Way Of Shree Chalala Vikas Seva Sahkari Mandli Ltd.

For Appellant: Ms. Devina Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR
Section 119(2)(b)Section 139(1)Section 139(4)Section 143(1)Section 143(1)(a)Section 250Section 80PSection 80P(2)(d)

JALGAON JILHA SAHAKARI COTTAN MARKETING FEDRATION,JALGAON vs. ITO, WARD1(4), JALGAON, JALGAON

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

ITA 616/PUN/2025[2018-19]Status: DisposedITAT Pune24 Sept 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.616/Pun/2025 धििेंारण वर्ा /Assessment Year: 2018-2019 Jalgaon Jilha Sahakari Ito, Ward 1(4), Cotton Marketing Jalgaon Fedration Limited, 135/1, Vs. Jilha Peth, Near S.B.I., Jalgaon-425001 Maharashtra Pan-Aadfj8195Q अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Smt. Deepa Khare Department By: Shri Ramnath P Murkunde Date Of Hearing: 24-09-2025 Date Of Pronouncement: 06-10-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 30.01.2025 Which Is Arising Out Of Order Passed U/S 143(3) Of The Act Dated 10.02.2021. 2. Assessee Has Raised Following Grounds Of Appeal:- 1. The Learned Cit(A) Has Erred On Facts & In Law In Confirming The Disallowance Of Deduction U/S 80P(2)(A)(Iv) Without Appreciating The Facts & Circumstances Of The Case. 2. The Learned Cit(A) Has Erred On Facts & In Law In Not Appreciating That The Non- Compliance Was Reasons Beyond The Control Of The Appellant. The Appellant Prays That Opportunity May Kindly Be Provided To Explain Its Case.

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ramnath P Murkunde
Section 142(1)Section 143(3)Section 250Section 80P(2)(a)

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