2026 (9) TMI 1308

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....1 passed u/s. 143(1) of the Income-tax Act, 1961 (hereinafter referred to as "the Act") by the Centralized Processing Centre, Bengaluru (hereinafter referred to as "the CPC"), relating to the Assessment Year 2019-20. 2. The brief facts giving rise to the present appeal are that the assessee is a Primary Agricultural Co-operative Society. For the assessment year under consideration, the assessee filed its return of income belatedly on 01.10.2020 declaring its income after claiming deduction of Rs. 1,18,55,220/- u/s. 80P of the Act. 3. The return so filed was processed by the CPC u/s. 143(1) of the Act vide intimation dated 22.10.2021, whereby the claim of deduction u/s. 80P of the Act was denied solely on the ground that the return of ....

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....delay in convening meetings of the Committee Members and obtaining the requisite approval for pursuing further appellate remedies, the appeal before the Tribunal could not be filed within the prescribed period. 6. We have carefully considered the affidavit filed by the assessee and the submissions advanced in support of the prayer for condonation of delay. It is well settled that while considering an application for condonation of delay, a liberal and justice-oriented approach ought to be adopted so that substantial justice is not defeated on account of technical considerations. Equally, it is trite law that the expression "sufficient cause" cannot be construed in a routine or mechanical manner and the party seeking condonation must esta....