2025 (4) TMI 2047

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.... assessment year is 2023- 2024. 2. There is a delay of 18 days in filing this appeal before the Tribunal. The assessee has filed a petition for condonation of delay supported by an affidavit of the Manager of the assessee-society stating therein the reasons for the belated filing of this appeal. 2.1 We have perused the affidavit filed by Manager of the assessee. We are of the view that there is sufficient cause for belated filing of this appeal and no latches can be attributed to the assessee. Hence, we condone the delay in filing this appeal and proceed to dispose of the same on merits. 3. The grounds raised read as follows:- "1. The order dated 3-10-2024 passed by the CIT(Appeals), National Faceless Appeal Centre, Delhi ....

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....on claimed under section 80P(2)(d) of the IT Act following the judgment of Karnataka High Court in Totagar Society's case [395ITR 611 and GujaratHigh Court in the case of Katlary Kiryana [327 CTR 128] 7. The CIT (Appeals) ought to have granted deduction for the entire claim of Rs. 1,22,96,065/- under section 80P of IT Act in respect of the interest/Dividend received on investments with Co-operative Banks following the decision of the Kerala High Court cited supra. 9. For these and other grounds to be urged at the time of hearing, it is most respectfully prayed that this Honorable Tribunal may be pleased allow the appeal granting deduction of Rs. 1,22,96,065/- under section 80P of the Act in respect of the interest/Divi....