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ITAT determined CPC exceeded jurisdictional authority in disallowing Section 80P deduction for cooperative society. Despite belated ITR filing, the tribunal found no legal basis for CPC to deny deduction under Section 80P(2). The impugned order was vacated, directing CPC to reverse disallowance and accept the claimed deduction under Chapter VI-A. The tribunal explicitly held that CPC lacked explicit statutory power to reject the deduction at the intimation stage under Section 143(1), thereby restoring the appellant's tax benefit.
ITAT determined CPC exceeded jurisdictional authority in disallowing Section 80P deduction for cooperative society. Despite belated ITR filing, the tribunal found no legal basis for CPC to deny deduction under Section 80P(2). The impugned order was vacated, directing CPC to reverse disallowance and accept the claimed deduction under Chapter VI-A. The tribunal explicitly held that CPC lacked explicit statutory power to reject the deduction at the intimation stage under Section 143(1), thereby restoring the appellant's tax benefit.
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