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2020 (9) TMI 409
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.... to the interests of the appellant is bad and erroneous in law and is against the facts and circumstances of the case. 2. That the learned Commissioner of Income-tax(Appeals) erred in law and on facts in not allowing the deduction of Rs. 32,39,442/- claimed u/s.80P(2)(a)(i) on the ground that the appellant is not a Co-operative Society. 3. That the learned Commissioner of Income-tax(Appeals) erred in law and on facts in making an addition of Rs. 5,72,250/-holding that the income earned from nominal members is not allowed as deduction u/s.80P(2)(a)(i) of the Act on the ground that such members do not hold voting rights and do not participate in the management of the appellant. 4. That the learned Commissioner of In....
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....carried on with its regular members would result in a loss of Rs. 17,43,445/- and the same is to be set off against the aforesaid income of Rs. 32,39,412/-. 2.2 Without prejudice to the ground that the appellant is entitled to deduction u/s. 80P of the Act, that the learned lower authorities ought to have computed the net income at Rs. 14,95,967/- instead of Rs. 32,39,412/-. 2.3 Without prejudice to the other grounds, that the disallowance cannot exceed Rs. 14,95,967/- being the deduction claimed u/s. 80P of the Act in the return of income. 3. Submissions on Admission of Additional Grounds 3.1 Ground No.1 - Ground regarding Limitation 3.1.1 This ground is legal in nature. The relevant facts and m....
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.... to raise these grounds on earlier occasion. By placing reliance on the judgment of the Supreme Court in the case of CIT vs. NTPC (229 ITR 383), I am inclined to admit the additional grounds on the reason that all the facts relevant to these grounds are on record and there is no necessity of fresh investigation. into all the facts relevant to these grounds. Accordingly, the additional grounds are admitted for adjudication. 7. Regarding the first additional ground, the facts of the case are that the assessment order in this case was passed after the due date of passing the assessment order. The assessee submitted that the due date for passing the assessment order was on 31/12/2017. According to the Ld. AR, though the assessment order was ....