Lanjani Co-operative Agri Service Society Ltd Vs DCIT (ITAT Chandigarh)
In a significant ruling affecting multiple co-operative societies, the Income Tax Appellate Tribunal (ITAT) Chandigarh has set aside orders from the National Faceless Appeal Centre (NFAC), Delhi, that had upheld the disallowance of Section 80P deductions solely due to the belated filing of income tax returns. The Tribunal’s consolidated decision, pronounced on August 30, 2022, emphasizes the critical aspect of statutory powers vested with the Centralized Processing Centre (CPC) for making such adjustments under Section 143(1) of the Income Tax Act, 1961.
The appeals, seven in total, including the lead case of Lanjani Co-operative Agri Service Society Ltd Vs DCIT, pertained to Assessment Years (AY) 2018-19 and 2019-20. The core issue across all cases was identical: the disallowance of deduction claimed under Section 80P by the CPC, Bengaluru, through an intimation issued under Section 143(1) of the Act.
In the lead case, Lanjani Co-operative Agri Service Society Ltd, a primary agricultural cooperative society, filed its income tax return for AY 2018-19 on October 13, 2018, declaring ‘nil’ income after claiming a deduction of Rs. 1,11,421/- under Section 80P. The due date for filing this return was August 31, 2018. The CPC subsequently processed the return and issued an intimation under Section 143(1) on May 31, 2019, disallowing the 80P deduction on the premise that the return was filed after the due date. Similar disallowances were made for the other six assessees for their respective assessment years.
