ITAT Chennai Restores Section 80P Deduction Matter to CIT(A) After Coordinate Bench Decision Overlooked — A. Kondalampatty Primary Agricultural Co-operative Credit Society Limited vs ITO
Case Overview
Court: Income Tax Appellate Tribunal, Chennai Bench
Case: A Kondalampatty Primary Agricultural Co-operative Credit Society Limited Vs ITO (ITAT Chennai)
Assessment Year: 2018-19
Outcome: Appeal allowed for statistical purposes; matter remanded to CIT(A) for fresh adjudication
Background and Facts of the Case
The present matter concerns a dispute arising from the assessment of A. Kondalampatty Primary Agricultural Co-operative Credit Society Limited, a primary agricultural co-operative credit society, for Assessment Year 2018-19. The assessee had filed its return of income on 11.10.2018, declaring its total income as 'Nil', having claimed deductions under the provisions of Section 80P(2)(a) and Section 80P(2)(d) of the Income-tax Act, 1961.
During the course of assessment proceedings, the Assessing Officer scrutinised the deduction claims put forth by the assessee. Upon examination, the Assessing Officer took the position that the assessee did not qualify for the deductions sought under Section 80P(2)(a) and Section 80P(2)(d). Consequently, these deductions were disallowed in their entirety.
As a direct consequence of the disallowance, a sum of ₹19,37,852/- was subjected to taxation under the head "Income from Other Sources", and the total assessed income was determined accordingly. The assessee, aggrieved by this outcome, pursued the appellate route.
Proceedings Before CIT(A)
The assessee carried the matter before the Commissioner of Income Tax (Appeals), NFAC, Delhi, seeking:
- Deletion of the addition made by the Assessing Officer
- Allowance of deductions claimed under
Section 80P(2)(a)andSection 80P(2)(d)of the Income-tax Act, 1961
However, the CIT(A), vide order dated 20.01.2026, dismissed the appeal on the primary ground that the assessee had not produced the requisite documentary evidence to substantiate its claims. On this basis, all additions and disallowances made at the assessment stage were upheld and confirmed.
Key Issue at CIT(A) Level: The appellate authority dismissed the appeal solely for want of supporting documents, without examining whether an existing coordinate bench ruling in the assessee's own case warranted a different outcome.
Dissatisfied with the outcome, the assessee preferred a further appeal before the ITAT Chennai Bench.