2024 (8) TMI 556

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....e Writ Petitions, the respective petitioners are Primary Agricultural Co-operative Credit Societies registered under the provisions of Tamil Nadu Co-operative Societies Act, 1983 and providing credit facilities to their members. 3. The case of the petitioners in all these Writ Petitions are that the petitioners are entitled to the deduction under Section 80P(2)(d) of the Income Tax Act, 1961 (hereinafter called as 'Act'). The respective petitioners have made investments in the Co-operative Banks, from whom, they have received interest and therefore, the case of the petitioner is that the respective petitioners are entitled to the deduction under Section 80P(2)(d) of the Act, on the interest received from the Co-operative Banks. 4. The....

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....tution with the new provisions with effect from 01.04.2022 is clear. Under Sub-clause (xiv) to Sub-section (1) to Section 144B of the Income Tax Act, 1961 as it stood prior to 01.04.2022 for the relevant period in dispute, the assessment unit was required to make a Draft Assessment Order after taking into account all relevant materials available on the records or in a case where intimation referred to in clause (xii) was received from the National Faceless Assessment Centre make a Draft Assessment Order to the best of its judgment, either accepting the income or was payable or was refundable to the assessee as per his Return or making such variation to the said income or same and send a copy of the said order to the National Faceless Assess....

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....etitioners have neglected assessment in as much as neither filed their Returns nor participated in the proceedings after the notices were issued under Section 148 of the Act and thus, the respective impugned orders have been passed. 12. The learned Standing Counsel for the respondent would also submits that the notices were issued to the addresses of the respective petitioners, which were received by them. Despite the same, the respective petitioners have not come forward to participate in the proceedings and thus, the respective impugned orders have been passed. 13. Having considered the submissions made by the learned counsel for the respective petitioners and the learned Standing Counsel for the respondent in all Writ Petitions, th....