Arungunam Primary Agricultural Cooperative Credit Society vs. ITO, NCW -22(1), Tambaram, Chennai

Parties Involved

Facts Summary

The assessee, Arungunam Primary Agricultural Cooperative Credit Society, is a primary agricultural co-operative credit society earning income from providing credit facilities to its members and farmers. It did not file its return of income for the assessment year 2019-20. The department noticed cash transactions amounting to Rs.1,52,70,000/- in the assessee's bank account. Consequently, a notice under section 148 of the Income Tax Act was issued by the Assessing Officer (AO), Non-Corp Ward 22(1), Tambaram. The assessee filed a belated return declaring total income as Rs.NIL/-. The AO disallowed deductions claimed under section 80P of the Act and completed the assessment by making an addition of Rs.1,32,633/-. Aggrieved by this, the assessee appealed to the Commissioner of Income Tax (Appeal), whose order was subsequently challenged in the present appeal.…

Legal Issues

• 1. Jurisdiction of the Jurisdictional Assessing Officer (JAO) in issuing the notice under section 148 of the Act in light of the CBDT Notification dated 29.03.2022 and relevant case laws.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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