Timely return requirement for co-operative deduction supports revision where reassessment ignored eligibility linked to cash-deposit income.
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....Revisionary jurisdiction under section 263 may be invoked where the assessment record gives a prima facie basis to regard an assessment as both erroneous and prejudicial to Revenue; final determination follows inquiry and hearing. A co-operative society deduction requires examination of the timely-return condition under section 80AC. Queries into cash deposits do not satisfy that obligation where they do not address the separate statutory eligibility condition, and a return furnished only after a reopening notice does not meet the prescribed filing requirement. Reassessment may examine the deduction when claimed co-operative income is offered to explain the cash deposits that prompted reopening. The revision was sustained and the appeal dismissed.....
TaxTMI