Kodanchery Panchayath Vanitha Co-op. Society Ltd. vs. The Income Tax Officer - 2(3)

Parties Involved

Facts Summary

The assessee’s appeal for A.Y. 2019-20 arises against the National Faceless Appeal Centre, Delhi [CIT(A)]’s DIN & Order No. ITBA/ NFAC/S/250/2023-24/1058297939(1) dated 29.11.2023 in proceedings u/s. 250 of the Income Tax Act, 1961 (the Act). Heard Both the parties. Case file perused. It emerges during the course of hearing at the outset that there is hardly any need for us to delve with the relevant factual matrix at length once it has come on record that both the learned lower authorities, more particularly, Assessing Officer [DCIT-CPC, Bangalore], have disallowed the assessee’s sec.80P deduction claim involving “processing” u/sec.143(1)(a)(v) of the Act. This is for the precise reason that the Finance Act, 2021 had in fact inserted the necessary amendment to this effect w.e.f. 01.04.2021 carrying prospective operation only whereas we are in assessment year 2018-2019.…

Legal Issues

• 1. Whether the disallowance of the assessee’s sec.80P deduction claim is sustainable in law?

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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