2025 (4) TMI 1084

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...."the Act") for the assessment year (A.Y.) 2014-15. Though, the assessee has raised multiple grounds of appeal, however, in our view the substantial grounds of appeal relate to deduction under section 80P(2)(d) only. 2. Rival submissions of both the parties have been heard and record perused. The learned authorised representative (ld AR) of the assessee submits that there is delay of 259 days in filing appeal before Tribunal. The ld CIT(A) passed the impugned order on 29.02.2024, however, this appeal was filed on 14.01.2025. the delay in filing appeal was not intentional or deliberate but due to the facts that impugned order was not communicated to the assessee on the e-mail provided on form -35 while filing appeal in 2016. The assessee p....

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.... taxmann.com 173 (SC), wherein it was held that credit co-operative society cannot be termed as cooperative Bank and that being credit society, it was entitled for exemption under section 80(P)(2). 4. On the other hand, learned senior departmental representative (Sr. DR) for the Revenue supported the order of lower authorities. The ld Sr DR for the revenue submits that there was inordinate delay in filing appeal before Tribunal. The assessee filed appeal belatedly. The assessee has not explained the delay in filing appeal before Tribunal in proper manner. The assessee is relying on self-serving story of not serving the order of ld CIT(A) on the e-mail address provided on form-35. Carful perusal of both the e-mail address clearly shows th....