Section 80P Denial Collapses After Section 119(2)(b) Condonation – CPC Intimation Cannot Survive

S55 Keerippatty Primary Agricultural Co-op. Credit Society Ltd. Vs ITO (ITAT Chennai) The ITAT Chennai set aside the CIT(A)’s order and held that once the delay in filing the return is condoned u/s 119(2)(b), the very basis for denying deduction u/s 80P disappears. The assessee, a Primary Agricultural Co-operative Credit Society (PACCS), filed its return for AY 2020-21 belatedly due to statutory audit under the TN Co-operative Societies Act being completed late. The CPC denied 80P in the 143(1) intimation solely because the return was not filed within the due date u/s 139(1). Subsequently, t...