Dagadudhondu Yeola Nagari Sahakari Patsanstha Maryadit Vs ITO (ITAT Pune)
CPC Cannot Deny 80P Deduction in 143(1) Before 01-04-2021 – Prima Facie Adjustment Held Invalid – ITAT Pune Allows Appeal
The ITAT Pune allowed the appeal of a co-operative society & held that CPC had no power to deny deduction under Chapter VI-A while processing return u/s 143(1)(a) prior to 01-04-2021. The CPC had disallowed deduction u/s 80P merely because the return was filed belatedly, but the Tribunal observed that such adjustment powers were introduced only by Finance Act 2021 through section 143(1)(a)(v).
Relying on several coordinate bench decisions, the Tribunal held that since the intimation denying deduction was issued before 01-04-2021, CPC exceeded its jurisdiction. Accordingly, the CIT(A)’s order was set aside & deduction u/s 80P amounting to ₹5,29,124/- was allowed, rendering alternate grounds infructuous.
Thus, the assessee’s appeal was allowed, reiterating that prima facie adjustments disallowing Chapter VI-A deductions were impermissible in pre-2021 processing.
FULL TEXT OF THE ORDER OF ITAT PUNE
The captioned appeal at the instance of assessee pertaining to the Assessment Year 2018-19 is directed against the order dated 11.08.2025 of National Faceless Appeal Centre, Delhi passed u/s.250 of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) arising out of the Rectification Order dated 03.08.2023 passed u/s.154 of the Act.
