This case revolves around the disallowance of a deduction claimed under Section 80P of the Income Tax Act by Shree Aggar Dhara Co-op Thrift & Credit Society Ltd, a cooperative society engaged in providing thrift and credit facilities to its members, for the assessment year 2018-19.
The appeal by the assessee was directed against the order of the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (INFAC), which upheld the adjustment made by the Central Processing Center (CPC) by disallowing the deduction claimed under Section 80P.
The main issue was the justification of the CPC’s decision under Section 143(1) of the Income Tax Act to disallow the deduction under Section 80P claimed by the society. The Tribunal noted that the representation by the assessee before the CIT(Appeals) was not effective and thus set aside the order, remanding the issue back to the Assessing Officer to reassess the deduction claim after considering the submissions of the assessee.
This decision highlights the critical importance of providing thorough and effective representation in appeals and the necessity for tax authorities to consider the specific provisions and the nature of cooperative societies under tax laws.
The Tribunal’s decision in ITA No. 2294/DEL/2022 underlines the procedural fairness required in tax assessments and the need for cooperative societies to meticulously document and justify their claims for deductions under Section 80P.
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