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Income Tax

ITAT Remands Section 80P Deduction Dispute as Earlier Tribunal Ruling Was Not Considered

Case Law Details

TaxGuru Citation
2026 taxguru.in 6746
Case Name
A Kondalampatty Primary Agricultural Co-operative Credit Society Limited Vs ITO (ITAT Chennai)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2018-19
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A Kondalampatty Primary Agricultural Co-operative Credit Society Limited Vs ITO (ITAT Chennai)

The Chennai Bench of the Income Tax Appellate Tribunal (ITAT) allowed the appeal of the assessee for statistical purposes and restored the matter to the Commissioner of Income Tax (Appeals) [CIT(A)] for fresh adjudication.

The assessee, A. Kondalampatty Primary Agricultural Cooperative Credit Society Limited, filed its return of income for Assessment Year 2018-19 on 11.10.2018 declaring total income at ‘Nil’. During the assessment proceedings, the Assessing Officer examined the assessee’s claim for deduction under Sections 80P(2)(a) and 80P(2)(d) of the Income-tax Act, 1961. The Assessing Officer concluded that the assessee was not entitled to the deductions claimed and consequently disallowed them. As a result, an amount of ₹19,37,852/- was brought to tax under the head “Income from Other Sources,” and the total income was determined accordingly.

Aggrieved by the assessment order, the assessee filed an appeal before the CIT(A), seeking deletion of the addition and allowance of the deductions claimed under Sections 80P(2)(a) and 80P(2)(d) of the Act.

The CIT(A), by order dated 20.01.2026, dismissed the appeal primarily on the ground that the assessee had failed to furnish relevant documentary evidence in support of its claim. Accordingly, the additions and disallowances made by the Assessing Officer were confirmed.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,782

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