2025 (4) TMI 1084

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..... mal, Sr. DR ORDER UNDER SECTION 254(1) OF INCOME TAX ACT PER PAWAN SINGH, JUDICIAL MEMBER 1. The appeal by the assessee is directed against the order passed by the Addl/JCIT(A)-1, Chandigarh /National Faceless Appeal Centre/ CIT(A) dated 29.02.2024 passed under section 250 of the Income Tax Act, 1961 ("the Act") for the assessment year (A.Y.) 2014-15. Though, the assessee has raised multiple gr .....

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..... know about the dismissal of their first appeal on 11.01.2015, when tax consultant forwarded email to the assessee. The assessee filed appeal immediately. The ld AR of the assessee submits that delay in filing of appeal may be condoned and the appeal may be heard on merit. 3. On merit, the learned ld. AR of the assessee submits that while filing return of income the assessee claimed deduction of .....

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..... support its submission. The ld. AR relied upon the decision of Hon'ble Apex Court in PCIT Vs Annasaheb Patil Matadi Kamgar Sahakari Pathpedi (2023) 150 taxmann.com 173 (SC), wherein it was held that credit co-operative society cannot be termed as cooperative Bank and that being credit society, it was entitled for exemption under section 80(P)(2). 4. On the other hand, learned senior departmental .....

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..... he submissions of both the parties and have gone through the orders of lower authorities. We have also deliberated on various case laws relied upon by the learned AR of the assessee. First, we shall consider the plea of assessee for condonation of delay in filing appeal before this Tribunal. We find that main contention of the ld AR of the assessee is that they have not received copy of order pass .....

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..... n consistently held that Co-operative Banks are primarily co-operative society and the interest or dividend earned from such Co-operative Bank are eligible for deduction under section 80P(2)(d). similar view was taken by coordinate bench of This Tribunal in Sai Ankur Co-operative Housing Society Limited vs. ITO (2025) 171 taxmann.co, 44 (Mumbai -Trib) and Karnataka High Court in PCIT Vs Totagars C .....

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