Tajpur S.K.U.S Ltd. Vs DCIT (ITAT Kolkata)
Income Tax Appellate Tribunal (ITAT), Kolkata Bench, has issued a significant ruling clarifying the scope of powers vested with the Centralized Processing Centre (CPC) for making prima facie adjustments. The Tribunal determined that the CPC lacked the authority to automatically deny the deduction claimed by co-operative societies under Section 80P of the Income Tax Act, 1961, for Assessment Year (AY) 2018-19, even if their income tax returns were submitted after the stipulated due date. The core of the ITAT’s decision rests on the temporal application of a key statutory amendment, which it found to be effective only from AY 2021-22.
The ruling, issued on January 13, 2025, resolved an appeal filed by Tajpur S.K.U.S. Ltd. against an order from the Commissioner of Income Tax (Appeals)-NFAC, Delhi. The central point of contention was the disallowance of ₹7,70,505/-, claimed by the co-operative society as a deduction under Section 80P for the assessment year in question.
Case Genesis: Belated Return and CPC Action
Tajpur S.K.U.S. Ltd. had filed its income tax return for AY 2018-19 on December 15, 2018. This submission was made 106 days after the statutory due date of August 31, 2018, prescribed by Section 139(1) of the Act. During the automated processing of the return under Section 143(1), the CPC initiated a prima facie adjustment, leading to the disallowance of the Section 80P deduction.
