2025 (3) TMI 1752

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....red to as "AY") 2018-19 & 2019-20 respectively. 2. Both the parties agreed that for both assessment years under challenge, the assessment orders as well as the Ld.CIT(A)'s order are similar/identical and therefore, the grounds of appeal are also similar for both years, hence AY 2019-20 is taken as the lead case and the decision of it, will decide the fate of AY 2018-19. 3. The main grievance of the assessee is against the action of the Ld.CIT(A)/NFAC disallowing the deduction claimed u/s.80P of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') of Rs. 10,04,281/- for AY 2019-20 and for AY 2018-19 [the AO disallowed deduction u/s.80P to the tune of Rs. 9,33,060/-]. 4. The brief facts are that the AO received information....

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....sits from its Members, and providing loan facilities to its Members in cash only. After going through the relevant documents filed by the assessee, the AO recorded his satisfaction about the source of the cash deposits as explained by assessee and didn't drew any adverse findings against the assessee. However, the AO denied the deduction claimed u/s.80P of the Act only on the ground that the assessee had belatedly filed RoI and didn't file the RoI within the due date as specified under sub-section (1) of sec.139 of the Act for relevant assessment year and therefore, disallowed Rs. 10,04,281/- for AY 2019-20 and likewise Rs. 9,33,060/- for AY 2018-19. 5. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who also reiterated ....