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    <title>2025 (5) TMI 340 - ITAT BANGALORE</title>
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    <description>Substantial delay in filing the first appeal was condoned because the assessee had bona fide pursued rectification under section 154, showing a genuine alternative remedy rather than negligence. The assessee was also held entitled to the extended due date under the second Explanation to section 139(1) because its accounts were required to be audited under the Karnataka Souharda Sahakari Act, 1997, a law in force apart from the Income-tax Act. The return filed within that extended period was treated as timely, so the denial of deduction under section 80P(2)(a)(i) solely for late filing was unsustainable, and relief was granted on both limitation and deduction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=770068</link>
      <description>Substantial delay in filing the first appeal was condoned because the assessee had bona fide pursued rectification under section 154, showing a genuine alternative remedy rather than negligence. The assessee was also held entitled to the extended due date under the second Explanation to section 139(1) because its accounts were required to be audited under the Karnataka Souharda Sahakari Act, 1997, a law in force apart from the Income-tax Act. The return filed within that extended period was treated as timely, so the denial of deduction under section 80P(2)(a)(i) solely for late filing was unsustainable, and relief was granted on both limitation and deduction.</description>
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