Tribunal Overturns Disallowance of Sec. 80P Deduction Claim for 2019-2020, Ruling Sec. 143(1)(a)(v) Not Applicable.

The ITAT ruled in favor of the appellant, overturning the disallowance of the sec. 80P deduction claim for the assessment year 2019-2020. The Tribunal determined that sec. 143(1)(a)(v) was not applicable since it was introduced with prospective effect from 01.04.2021, thus allowing the appellant's deduction claim.

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Issues Involved:
The appeal involves the disallowance of sec. 80P deduction claim under sec. 143(1) of the Income Tax Act, 1961 for assessment year 2019-2020.

Analysis:
The Revenue contended that the sec. 80P deduction claim of the assessee was rightly disallowed for not filing the sec. 139(1) return within the due date. They argued that such claim could be disallowed under sec. 143(1)(a)(ii) of the Act if it is incorrect. Reference was made to sec. 80AC and a judgment in Veerappampalayam Primary Agricultural Cooperative Credit Society Vs. DCIT to support their position.

However, the Tribunal found no merit in the Revenue's arguments. It noted that the disallowance provision in sec. 143(1)(a)(v) dealing with deduction claims under Chapter-VI-A was introduced by the Finance Act, 2021 with prospective effect from 01.04.2021, while the assessment year in question was 2017-2018. Therefore, the Tribunal held that sec. 143(1)(a)(v) was not applicable to the assessee's case. Citing the principles of stricter interpretation, the Tribunal concluded that the disallowance of the sec. 80P deduction claim by the lower authorities was incorrect and ordered it to be reversed.

As a result, the Tribunal allowed the assessee's appeal, overturning the disallowance of the sec. 80P deduction claim.

Separate Judgement:
No separate judgment was delivered in this case.

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