2025 (8) TMI 453

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....RABLE MR. JUSTICE ZIYAD RAHMAN A.A. For the Appellant : Adv Shri. C. A. Jojo For the Respondents: Advs. Christopher Abraham, Income Tax Department and Shri. P.R. Ajith Kumar JUDGMENT The petitioner is a co-operative society engaged in the business of providing credit services to its members. As per Rule 15 of the Kerala Co-operative Societies Rules, the petitioner has been classified a....

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....he assessing officer, for allotment of a fresh PAN number showing the status of the petitioner as a co-operative society. The said communication is dated 15.12.2020, and acting upon the same, a fresh PAN card was issued with number AAIAK3165H, which is produced as Ext.P1(3). Later, Ext.P2 notice under Section 148 of the Income Tax Act, 1961 was issued to the petitioner on 30.03.2021 by referring t....

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.... Tax Act, 1961. 4. A statement has been filed by the learned Standing Counsel for the respondent on behalf of the respondent. In the statement, it is specifically averred that the relief sought by the petitioner is opposed. According to the respondents, the petitioner cannot claim the benefit of Section 80P, as they failed to furnish the returns in respect of the relevant financial year. Theref....

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.... issued with a new PAN card, wherein, the status of the petitioner was shown as the AOP (Association of Persons). Therefore, the specific contention of the petitioner is that they could not effectively contest the matter due to various technical reasons due to descrpencies that arose consequent to the transactions that are carried out in PAN card which was cancelled and was issued without showing ....