2026 (5) TMI 1000

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....pondent : Shri Surjit Kumar Saha (through virtual) ORDER The captioned appeal at the instance of assessee pertaining to A.Y. 2013-14 is directed against the order dated 17.10.2023 framed by National Faceless Appeal Centre, Delhi (NFAC) arising out of Rectification Order dated 19.02.2024 passed u/s. 154 r.w.s.250 of the Income Tax Act, 1961 (in short 'the Act'). 2. Registry has pointed out....

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....appeal for adjudication. 3. The grievance of the assessee are two fold, firstly the reassessment order u/s. 147 of the Act when the facts were already available and have been examined during the course of assessment proceedings u/s. 143(3) of the Act and secondly the disallowance of claim of deduction u/s. 80P of the Act at Rs. 2,31,994/-. 4. I have the heard the rival contentions and peruse....

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....Rs. 7,31,994/-. Based on this information, re-assessment proceedings were carried out and even though the assessee challenged the reopening, however, ld. Assessing Officer concluded the proceedings withdrawing the deduction u/s. 80P of the Act at Rs. 7,31,994/- and assessed the income u/s. 147 of the Act at Rs. 7,60,200/-. Aggrieved assessee preferred appeal before ld.CIT(A) but failed to succeed ....

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....sessee which is a Cooperative Society and even if certain expenses are disallowed giving raise to the increase in income, the source of such income is from the activity of a Cooperative Society itself and the increased net profit is normally eligible for deduction u/s. 80P of the Act. 6. Here, I would like to take into consideration the CBDT Circular No.37/2016 dated 02.11.2016 under the headin....