TaxTMI 
TaxTMI 
2024 (8) TMI 807
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....g an effective appropriate opportunity for hearing, thus violating the principle of natural justice. Appellant contends that, notices, of hearing sent by CIT(A) never reached to the Appellant considering various communication challenges and peculiar facts that the same were sent on the email id of erstwhile employee/consultant and mofussil area of activity. 2. The learned CIT(A) erred in law and on facts in upholding the disallowance of deduction u/s 80P(2)(a)(i)/80P(2)(d) amounting to Rs. 68,24,572/-. The learned CIT(A) ought to have appreciated the fact that the appellant is eligible for claiming such deduction u/s 80P. 3. The learned CIT(A) erred in law and on facts in not appreciating that deduction u/s 80P(2)(a) and 80P(2)(d) has b....
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....embers and also the details of interest earned from investments with co-operative societies and from other banks. The appellant failed to file any reply/submission in respect of the said notice. Accordingly, after due examination of facts and law the Assessing Officer passed order u/s 143(3) wherein the claim of deduction u/s 80P(2) of the IT Act was disallowed and additions were also made u/s 40(a)(ia) of the Act on account of failure to deduct tax at source on rent and audit fee payments. 4. Being aggrieved, an appeal was filed before LD CIT(A)/NFAC. Notices were issued but the assessee could not appear on the date of hearings due to the fact that the email belongs to the erstwhile employee of the society, who did not inform the society ....
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....rashtra State Cooperative Societies Act & carrying on the business of providing credit facility to the members & also accepting the deposits from them. During the course of assessment proceedings the assessee could not reply to some of the queries of the AO regarding bifurcation of interest earned from members & non-members & also the details of interest earned from investment with cooperative societies & from other banks, therefore, the AO denied the deduction u/s 80P(2)(a)(i) of the IT Act. Further, disallowance u/s 40(a)(ia) for non-deduction of TDS on Audit fees payment & Rent payment was also made. We find that the definition of member as per Maharashtra State Cooperative Societies Act includes nominal members also & therefore the inte....