TaxTMI 
TaxTMI 
2014 (7) TMI 246
X X X X Extracts X X X X
X X X X Extracts X X X X
.... (Appeals)-23, Mumbai [CIT(A)] erred in refusing to condone delay of the appellant in filing appeal before him. 2. The CIT(A) erred in not appreciating the fact that appellant had valid grounds for delay in filing appeal which deserved to be condoned on principles of natural justice. Re-opening of assessment 3. Without prejudice to the aforesaid, the CIT(A) erred in not adjudicating on ground nos. 01 to 08 in which it was stated that re-opening of assessment was not valid and bad in law. 4. The CIT(A) erred in not appreciating the fact that the AO proceeded to complete the assessment proceedings and pass an order without furnishing to the appellant the reasons recorded for issue of notice under section 148 although after having issued th....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... respect of interest earned on staff loan of Rs. 1,31,886/- interest earned on savings bank account of Rs. 10,231/- and interest on staff housing loan of Rs. 64,098/-. 10.The CIT(A) erred in failing to appreciate that the appellant society is engaged in the activity of providing credit facilities to its members which as per the Bombay Cooperative Societies Act, 1925 includes ordinary members, nominal members and sympathizer members. Denial of deduction under section 80P(2)(c)(ii) of the Act 11. Without prejudice to the aforesaid, the CIT(A) erred in not adjudicating on ground no. 17 in which it was stated that the AO erred in denying the appellant deduction under section 80P(2)(c)(ii) of the Act. Charging of interest 12. Without prejud....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... loan of Rs. 1,98,379/-, interest earned on savings bank account of Rs. 7,781/- and miscellaneous receipts of Rs. 100/-. 4. The CIT(A) erred in failing to appreciate that the appellant society is engaged in the activity of providing credit facilities to its members which as per the Bombay Cooperative Societies Act, 1925 includes ordinary members, nominal members and sympathizer members. Charging of interest 5. Without prejudice to the aforesaid the CIT(A) erred in not adjudicating on ground no. 09 in which it was stated that the AO erred in failing to appreciate that no interest is chargeable under sections 234B and 234C of the Act in case there is a default in payment of advance tax on account of additions or disallowances made in the a....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ssment year 2003-04 was decided in favour of the assessee as the issue involved was recurring issue, the Ld. AR of the assessee advised to file an appeal against levy of the tax. Accordingly, the appeals were filed and it was requested that delay should be condoned and appeal should be admitted. After considering such submissions Ld. CIT(A) has observed that it is not a fit case for condonation of delay. He found that verification in form No.35 was signed by the Society on 2/3/2012, whereas the appeal was filed on 19/03/2012. He observed that there is a substantial time gap between the date of signing of the form of verification and the date of actual filing of the appeal and such delay has not been explained and for that no reasons has bee....