2021 (7) TMI 1167

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..... The assessee has raised the following substantive grounds in the instant appeal: "1. The Ld.CIT(A) erred on facts and law in upholding additions made by the AO towards the disallowance of appellant's claim of deductions u/s 80(P)(2)(d) and 36(1)(vii)(a) of the Income Tax Act, 1961. 2. The Ld.CIT(A) erred in upholding the decision of the AO in disallowing appellant's claim of deduction u/s 80(P)(2)(d) of the I.T. Act, 1961, without adjudicating the grounds of the appellant before him, without stating the reasons for upholding the decision of the AO and simply by stating that he is in total agreement with the AO. 3. The Ld.CIT (A) ought to have appreciated the fact that on the facts and circumstances of th....

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....reciated the fact that the AO erred in denying deduction u/s 80(P)(2)(d) of the I.T. Act, 1961, which was claimed by the appellant in the capacity of CO-OPERATIVE SOCIETY, though it falls within the meaning of a co-operative bank under the Banking Regulation Act, 1961. 9. The Ld.CIT (A) ought to have appreciated the fact that the AO erred in denying deduction u/s 80(P)(2)(d) of the LT. Act, 1961, by applying the provisions of 80P(4) of the LT. Act, 1961, without understanding the fact that the contention of the appellant is not based on classification, and it is based on deduction available to it as a cooperative society against its investments with the other co-operative societies. 10. The Ld.CIT(A) ought to have apprecia....

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....ion of the A.O in disallowing deduction u/s 36(1)(viia) of the I.T. Act, 1961 by stating that the appellant has not made any provision for bad and doubtful debts in its books of accounts. 15. The CIT(A) ought to have appreciated the fact that making provision for bad and doubtful debts in the books is not mandatory when the appellant is claiming deduction uls 80P(2)(d) of the I.T. Act, 1961. 16. The CIT(A) ought to have considered the information and workings furnished by the appellant in support of its claim of deduction towards provision for bad and doubtful debts u/s 36(1)(viia) of the I.T. Act, 1961. 17. The Appellant may add or alter or amend or modify or substitute or delete and/or rescind all or any of the ....