https://www.taxtmi.com/caselaws?id=754589 The ITAT Bangalore allowed the assessee's appeal against a rectification order under section 154 denying deduction under section 80P. The AO failed to provide material evidence showing the original deduction was a mistake apparent from record. While the AO cited Supreme Court precedents regarding denial of 80P benefits for dealing with non-members, he ignored the subsequent Mavilayi Service Co-operative Bank Ltd judgment allowing proportionate deduction. The AO's show cause notice didn't establish that the assessee violated mutuality principles by dealing with non-members. The ITAT held the issue was debatable and not an obvious, patent mistake amenable to section 154 rectification proceedings. en-us Wed, 17 Jan 2024 00:00:00 +0530 Thu, 27 Jun 2024 08:54:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754589 The ITAT Bangalore allowed the assessee's appeal against a rectification order under section 154 denying deduction under section 80P. The AO failed to provide material evidence showing the original deduction was a mistake apparent from record. While the AO cited Supreme Court precedents regarding denial of 80P benefits for dealing with non-members, he ignored the subsequent Mavilayi Service Co-operative Bank Ltd judgment allowing proportionate deduction. The AO's show cause notice didn't establish that the assessee violated mutuality principles by dealing with non-members. The ITAT held the issue was debatable and not an obvious, patent mistake amenable to section 154 rectification proceedings. Case-Laws Income Tax Wed, 17 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754589