TaxTMI 
TaxTMI 
2025 (2) TMI 1884
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....:- "1. On the facts and in law, Ld. CIT(A) erred in confirming order u/s 143(3) passed by Ld. A.O as valid though the same was bad in law. 2. On the facts and circumstances of the case and in law, Ld. A.O erred in disallowing the deduction claimed by the appellant without mentioning the clear and legal reason for the same and thus Ld. CIT(A) also erred in confirming such order as valid. 3. On the facts and in law, Ld. A.O erred in disallowing the deduction claimed by the appellant only on the basis of whims and surmises, without following the settled principle of consistency. 4. The appellant craves leave to add, alter, vary, omit, amend or delete one or more of the grounds of appeal before, or at the tim....
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....otices of hearing were not received by the Assessee. The Assessee was not aware of CIT(A) order passed dated 30/01/2024. D. It is submitted that the Assessee's taxation related compliance matters were primarily looked after by member Shalu Chhatrapal Maragaye, who unfortunately passed away on 23/11/2023. A copy of the death certificate is enclosed for reference. Due to her demise, there was a period of transition wherein the Assessee had to reorganize its internal compliance structure, update email credentials, and appoint a new representative to handle taxation matters. E. After the unfortunate demise of the concerned person, it took some time to identify and retrieve official communications, change registered email a....
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....e is taken by the Assessee. Accordingly. in the interest of justice, the Assessee wishes to challenge the assessment order passed by the learned CIT(A) by way of appeal filed before your Honour with a request for condonation of delay. In view of this, it is prayed that the delay of 30 days may kindly be condoned in order to render the justice." 4. There is sufficient and reasonable cause for condoning the delay, accordingly we do so. 5. Before us, Shri Abhay Agrawal, Counsel appearing for the assessee invited our attention to the relevant portion of the impugned order passed by the learned CIT(A) which is reproduced below for ready reference:- "5.2. APPELLANT'S SUBMISSION: The appellant did not make any ....
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....ciety Ltd. vs. Income-tax Officer (SC) (2010)188 Taxman 282 wherein the Apex Court held that interest income from deposits with banks cannot be held to income from business for the appellant. As held in case of Principal Commissioner of Income-tax, Hubballi v. Totagars Co-operative Sale Society [2017] 83 taxmann.com 140 and Gujarat HC in case of Katlary Kariyana Merchant Sahkari Sarafi Mandali Ltd. (2022) 140 taxmann.com 60, interest income from any entity (including cooperative banks) apart from just cooperative societies is not eligible for deduction u/s 80P. 5.3.2. The appellant has failed to provide any proof of fulfilling the above conditions. When an exemption is claimed, the burden lies on the party claiming the exe....