Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Selection of a notice under section 143(2) for limited scrutiny was valid because it targeted verification of a claim for deduction, and that ground of appeal was dismissed. The assessees' claim for deduction under 80P as a members' credit cooperative society was sustained by reliance on High Court precedents; the AO is directed to allow the deduction. Interest income derived from providing credit to members should be treated as business income and allowed as a deduction under the cooperative-deduction head rather than under an alternate head; AO is directed to grant deduction accordingly. Accounting provisions for interest and mandated provisioning for non performing advances comply with accrual accounting and statutory mandates, and related disallowances are deleted.
Selection of a notice under section 143(2) for limited scrutiny was valid because it targeted verification of a claim for deduction, and that ground of appeal was dismissed. The assessees' claim for deduction under 80P as a members' credit cooperative society was sustained by reliance on High Court precedents; the AO is directed to allow the deduction. Interest income derived from providing credit to members should be treated as business income and allowed as a deduction under the cooperative-deduction head rather than under an alternate head; AO is directed to grant deduction accordingly. Accounting provisions for interest and mandated provisioning for non performing advances comply with accrual accounting and statutory mandates, and related disallowances are deleted.
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