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2026 (8) TMI 747

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....e-tax Act, 1961 (hereinafter referred to as 'the Act' in short) for Assessment Year 2024-25. 2. The Assessee has raised the following grounds of Appeal:- 1. The Learned Commissioner of Income Tax (Appeals) erred in law and on facts in confirming the section 80P deduction disallowance of Rs. 5,59,600/- such deduction is requested to be allowed. 3. The facts of the case are that the assessee, a co-operative society, filed its return of income for the Assessment Year 2024-25 on 03.07.2024 declaring Nil income after claiming deduction of Rs. 5,59,660/- under section 80P of the Income-tax Act, 1961. While processing the return under section 143(1) of the Act, the Central Processing Centre (CPC), Bengaluru, disallowed the deduction....

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.... the conditions contained in sub-section (2) in computing its income in any previous year, the option shall become invalid in respect of the assessment year relevant to that previous year and subsequent assessment years and other provisions of the Act shall apply, as if the option had not been exercised for the assessment year relevant to that previous year and subsequent assessment years. (2) For the purposes of sub-section (1), the total income of the co-operative society shall be computed,- (i) without any deduction under the provisions of section 10AA or clause (iia) of sub-section (1) of section 32 or section 32AD or section 33AB or section 33ABA or sub-clause (ii) or sub-clause (iia) or sub-clause (iii) of sub-sectio....

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....itions contained in subsection (2) shall be modified to the extent that the deduction under the said section shall be available to such Unit subject to fulfilment of the conditions contained in that section. Explanation.-For the purposes of this sub-section, the term "Unit" shall have the meaning assigned to it in clause (zc) of section 2 of the Special Economic Zones Act, 2005 (28 of 2005). (5) Nothing contained in this section shall apply unless option is exercised by the person in such manner as may be prescribed on or before the due date specified under sub-section (1) of section 139 for furnishing the return of income for any previous year relevant to the assessment year commencing on or after the 1st day of April, 20....