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K 1104 Elayamuthur Primary Agricultural Co-operative Credit Society v. Income Tax Officer

Case No: ITA Nos. 1040 & 1041/Chny/2024
Court: Income Tax Appellate Tribunal, 'C' Bench, Chennai
Date: 9/18/2024

Parties Involved

appellantK 1104 Elayamuthur Primary Agricultural Co-operative Credit Society
respondentIncome Tax Officer, Ward -2(4), Tirupur

Facts Summary

The assessee, K 1104 Elayamuthur Primary Agricultural Co-Op Credit Society, filed returns for the assessment years 2016-17 and 2017-18, claiming deductions under Section 80P of the Income Tax Act. The returns were processed, and the cases were selected for scrutiny. The Assessing Officer issued notices to the assessee, who submitted relevant details. The AO framed an assessment under Section 143(3) of the Act, disallowing the entire deduction claimed under Section 80P. The assessee appealed to the Commissioner of Income Tax (Appeals), who allowed some deductions but confirmed the disallowance of certain deductions. The assessee further appealed to the Income Tax Appellate Tribunal.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the order of the Commissioner of Income Tax (Appeals) is erroneous in law.
  • 2. Whether the Commissioner of Income Tax (Appeals) erred in not considering the submissions made by the appellant.
  • 3. Whether the Commissioner of Income Tax (Appeals) erred in deciding that the appellant is not entitled for deduction under Section 80P(2)(d).
  • 4. Whether the Commissioner of Income Tax (Appeals) erred in not following the decision of the jurisdictional High Court.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

4 precedents cited in this judgement.

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