TaxTMI 
TaxTMI 
2026 (9) TMI 1164
X X X X Extracts X X X X
X X X X Extracts X X X X
....e following grounds of appeal : "Each ground is taken without prejudice to each other. On the facts and in the circumstances of the case and in law and 1. The learned AO has erred in denying / rejecting claim of deduction made by assessee in ITR under section 80P(2) of Rs. 31,46,806/- and the learned CIT (A) erred in confirming the same. 2. There is an error of assessing and taxing entire income of assessee from its activities which is otherwise not taxable under principle of mutuality and under the governing provisions of law being a registered Co-op. credit society. 3. The learned AO has erred in disallowing the deduction claimed by assessee u/s 80P(2) and erred in rectifying such claim despite....
X X X X Extracts X X X X
X X X X Extracts X X X X
....t on 17/02/2023 resulting in demand of Rs. 6,47,810/- after disallowing the deductions of Rs. 31,46,806/- claimed by the assessee u/s 80P of the Act in its ITR. The assessee has filed rectification application in this office requesting for allowing 80P deductions amounting Rs. 31,46,806/- claimed by the assessee in its ITR and nullifying the demand raised by CPC. On verification through intimation order u/s 143(1) dated 17/02/2023, it is noted that the assessee had filed its original ITR on 26/12/2022 after the extended due date i.e. 07/11/2022 due to which CPC had disallowed the deductions of Rs. 31,46,806/- claimed by the assessee u/s 80P in its ITR and hence as per section 80AC of the I.T. Act, the claim of the assessee for allo....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Chapter under the heading "C.-Deductions in respect of certain incomes", no such deduction shall be allowed to him unless he furnishes a return of his income for such assessment year on or before the due date specified under sub-section (1) of section 139." 6. Thus, as per section 80AC of the Act, no deduction is admissible unless return of income is filed on or before the due date specified u/s 139(1) of the Act. 7. Section 143(1) of the Act is reproduced here as under : "Assessment. 143. (1) Where a return has been made under section 139, or in response to a notice under sub-section (1) of section 142, such return shall be processed in the following manner, namely:- (a) the total income or loss sh....