2024 (5) TMI 553

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.... For the Respondent : Smt. J.M. Jamuna Devi, Sr. DR. ORDER PER ANIL KUMAR DUGAR, JM : This appeal at the instance of the assessee is directed against the Commissioner of Income-tax (Appeals)'s ["CIT(A)]" for short] order dated 25.08.2022 passed u/s 250 of the Income-tax Act, 1961 ("the Act" for short). The relevant assessment year is 2019-2020. 2. The sole issue in the instant appeal....

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....tion to this effect. 4. The brief facts of the case are that the assessee is a Primary Rural Agricultural Co-operative Credit Society duly registered u/s 7(1) of the Kerala Cooperative Society Act, 1961 (Act 21 of 1969) having registration no. K1119 dated 10-02-2012, as appears from the certificate dated 31-08- 2021 issued by the Assistant Registrar of Co-operative Societies (General), Changana....

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....n u/s. 80P in the Schedule 'BP' relating to computation of income, implies that it regards it's relevant income as taxable, i.e., forming part of gross total income, and claims deduction u/s. 80P there-against. The mismatch in it's return inasmuch as the same finds mention in the schedule of 'Exemption', rather than 'Deduction', can thus only be regarded as mistaken, to which, in context, the doct....

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....tment must not take the advantage of the ignorance of an assessee to collect more tax than what is legitimately due. This also reflects the uniform view of the Hon'ble Courts, as in Parekh Brothers v. CIT [1984] 150 ITR 105 (Ker), exhorting the Revenue to assist the tax payer in every way, particularly in the matter of claiming and securing relief. While in the instant case, the assessee is being ....