Partial success in tax appeals for assessment years, remand for profit deduction, and re-adjudication of other income eligibility.

The Tribunal partly allowed the appeals for the assessment years in question, condoning the delay in filing due to valid reasons. The deduction of profit from PDS activities was remanded to consider proportionate expenses. The disallowance of dividend income from a cooperative bank was vacated, following relevant precedent. The issue of other income was remanded for re-adjudication by the AO to determine the extent eligible for deduction under relevant sections. The AO was directed to re-assess deductions based on the Tribunal's findings.

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Issues Involved:
1. Condonation of Delay.
2. Deduction of Profit from PDS under Sec. 80P(2)(c).
3. Deduction of Dividend Income under Sec. 80P(2)(d).
4. Deduction of Other Income under Sec. 80P(2).

Condonation of Delay:
The appeals were time-barred by 10, 35, 37, and 38 days respectively. The delay was due to the appellant's remote location and their engagement in paddy procurement activities. The Tribunal found the reasons satisfactory and condoned the delay.

Deduction of Profit from PDS under Sec. 80P(2)(c):
The assessee's claim for deduction of Rs. 38,88,571/- from PDS activities was remanded to the AO to restrict the deduction to the net profit after considering proportionate expenses, following the precedent set in Gramin Sewa Sahakari Samiti Maryadit & Ors Vs. ITO.

Deduction of Dividend Income under Sec. 80P(2)(d):
The Tribunal vacated the disallowance of Rs. 1,30,800/- on dividend income received from Jila Sahakari Bank, following the decision in Gramin Sewa Sahakari Samiti Maryadit & Ors Vs. ITO, which held that dividend income from a co-operative bank is eligible for deduction under Sec. 80P(2)(d).

Deduction of Other Income under Sec. 80P(2):
The Tribunal remanded the issue of Rs. 9,05,369/- other income, which includes recovery from NPA accounts and receipts against paddy procurement, to the AO for re-adjudication. The AO is to determine the extent of the income eligible for deduction under Sec. 80P(2)(a)(iii) and Sec. 80P(2).

Conclusion:
The appeals for the assessment years 2012-13, 2013-14, 2015-16, 2016-17, and 2017-18 were partly allowed for statistical purposes, with directions for the AO to re-assess the deductions based on the Tribunal's observations.

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