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Income Tax : CBDT issues Circular No. 14/2024 allowing condonation of delay in filing tax returns for AY 2023-24 under Section 80P, benefiting ...
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ITAT held that interest earned on deposits kept as security for obtaining business loans was attributable to the cooperative society’s business activity. The income was therefore eligible for deduction under Section 80P(2)(a)(i).
Pune ITAT ruled that interest earned by a cooperative society from investments with cooperative banks is deductible under Section 80P(2)(d). The decision reinforces the broad scope of the provision.
The Tribunal ruled that condonation of delay by the competent authority removes the statutory obstacle created by Section 80AC for late-filed returns. As a result, the assessee’s claim for deduction under Section 80P must be reconsidered in accordance with law.
The Tribunal ruled that disallowance of deduction under Section 80P was beyond the permissible scope of prima facie adjustments under Section 143(1). Relief was granted to the assessee.
ITAT held that a typographical mistake in selecting the wrong sub-clause of Section 80P does not defeat a valid deduction claim. The Tribunal directed the Revenue to grant the full deduction where eligibility was otherwise undisputed.
The Tribunal ruled that the Assessing Officer wrongly invoked Section 154 to withdraw deduction on interest income from co-operative banks. Since the issue is subject to differing judicial interpretations, it falls outside the scope of rectification.
The Tribunal criticized the Assessing Officer for taking a contrary stand in later years after allowing the same deduction on identical facts in an earlier assessment. It held that such inconsistent treatment without distinguishing facts was unsustainable.
The ITAT dismissed the appeal after a rectification order under Section 154 granted the deduction under Section 80P and corrected the assessed income. The dispute no longer survived for adjudication.
The ITAT held that deduction under Section 80P could not be disallowed through a unilateral adjustment under Section 143(1) without providing notice and an opportunity of hearing. The appeals were allowed.
The Tribunal ruled that surplus funds parked in banks by a co-operative credit society retain the character of business income when linked to member credit activities. Deduction under Section 80P(2)(a)(i) was therefore allowed.
