ITAT Refuses to Condone 7-Year Delay in Section 80P(2) (d) Dispute; Company Fails to Justify Massive Delay:

ITAT Mumbai rejects five appeals of the company for an unexplained 7-year delay, denying consideration of the Section 80P(2)(d) deduction claim.
Tribunal Dismisses All Five Appeals being Time-Barred

ITAT Refuses to Condone 7-Year Delay in Section 80P(2) (d) Dispute; Company Fails to Justify Massive Delay
The present five appeals have been filed by a company named Vissanji A 1 Friends Cooperative Housing Society Limited before the Income Tax Appellate Tribunal (ITAT), Mumbai, relating to the Assessment Years 2011-12 to 2015-16. The final decision on the matter was announced on November 19, 2025.
All appeals were against intimation orders passed under section 143(1), where the CPC disallowed the society’s claim of deduction under section 80P(2)(d) relating to interest income from co-operative banks. All first appeals before the CIT(A) were dismissed because they were filed after a massive delay of around 7 years, and the CIT(A) refused to condone the delay. The final decision on the matter was announced on November 19, 2025.
Across all the years, the assessee raised common ground:
- CIT(A) wrongly rejected appeals due to delay.
- CIT(A) wrongly applied section 80AC, saying late return filing makes the 80P claim invalid, though 80AC was not applicable for years before AY 2018-19;
- CPC wrongly disallowed deduction u/s 80P(2)(d) in 143(1) processing, which is not allowed as a “prima facie adjustment”;
- For some years, credit for the self-assessment tax credit was not given.
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Saloni Kumari
Content Writer
Saloni is a Content Writer with 2+ years of experience at studycafe.in. She writes legal, taxation, and finance related content including GST, Income Tax etc. Skilled in translating complex judicial pronouncements and regulatory developments into clear, and reader-friendly articles. Experienced in covering judgements of ITAT, High Court, GSTAT, and news related to Income Tax, GST, and corporate law. She can be reached at [email protected].
Saloni is a Content Writer with 2+ years of experience at studycafe.in. She writes legal, taxation, and finance related content including GST, Income Tax etc. Skilled in translating complex judicial pronouncements and regulatory developments into clear, and reader-friendly articles. Experienced in covering judgements of ITAT, High Court, GSTAT, and news related to Income Tax, GST, and corporate law. She can be reached at [email protected].
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