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    <title>2024 (4) TMI 51 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad allowed assessee&#039;s appeals regarding rectification application u/s 154 that was rejected as time-barred. The tribunal held that limitation period begins only when assessee receives the order, and department failed to prove service of intimation u/s 143(1). Since assessee consistently challenged demand notices within four years and department provided no service details, the application was within time. On merits, assessee&#039;s Section 80P deduction was wrongly denied as authorities failed to consider that profits included income from providing credit facilities to members, not just bank interest. Matter remanded to AO for fresh consideration with proper hearing opportunity.</description>
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    <pubDate>Thu, 28 Mar 2024 00:00:00 +0530</pubDate>
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      <title>2024 (4) TMI 51 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=750870</link>
      <description>ITAT Ahmedabad allowed assessee&#039;s appeals regarding rectification application u/s 154 that was rejected as time-barred. The tribunal held that limitation period begins only when assessee receives the order, and department failed to prove service of intimation u/s 143(1). Since assessee consistently challenged demand notices within four years and department provided no service details, the application was within time. On merits, assessee&#039;s Section 80P deduction was wrongly denied as authorities failed to consider that profits included income from providing credit facilities to members, not just bank interest. Matter remanded to AO for fresh consideration with proper hearing opportunity.</description>
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      <pubDate>Thu, 28 Mar 2024 00:00:00 +0530</pubDate>
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