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    <title>2026 (4) TMI 905 - ITAT BANGALORE</title>
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    <description>Delay of 59 days in filing the appeals was accepted because the assessee&#039;s explanation, based on audit completion, AGM proceedings and internal deliberations on further challenge, was found plausible and sufficient. The matter concerning the assessee society&#039;s PAN status, return filing position and claim of deduction under section 80P was remanded for de novo consideration because the factual controversy had not been properly examined by the lower authorities and the disallowance rested largely on the absence of a return under section 139(1). The Assessing Officer was directed to reconsider the issues in accordance with law after giving reasonable opportunity of hearing.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789836</link>
      <description>Delay of 59 days in filing the appeals was accepted because the assessee&#039;s explanation, based on audit completion, AGM proceedings and internal deliberations on further challenge, was found plausible and sufficient. The matter concerning the assessee society&#039;s PAN status, return filing position and claim of deduction under section 80P was remanded for de novo consideration because the factual controversy had not been properly examined by the lower authorities and the disallowance rested largely on the absence of a return under section 139(1). The Assessing Officer was directed to reconsider the issues in accordance with law after giving reasonable opportunity of hearing.</description>
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