THOTTATHIL B. RADHAKRISHNAN, J.

1. These appeals by primary agricultural credit societies registered and classified as such under the provisions of the Kerala Co-operative Societies Act, 1969, for short, 'KCS Act' relate to exemptions claimed by them with reference to section 80P(4) of Income Tax Act, 1961; hereinafter, 'IT Act'. Issues are also raised relating to the validity or otherwise of the returns filed by the assessees beyond the period stipulated under section 139(1)/(4) or section 142(1)/148 for the purpose of deciding exemption under section 80P of the IT Act. Incidental issues relating to doubtful debts proportionate to the gross total income and the status of rural branch to claim deduction referable to section 36 (1)(viia) of the IT Act are also raised.

2. Heard Snr. Adv. Firoze B. Andhyarujina and Snr. Adv. T.M. Sreedharan and other learned advocates for the appellants and Snr. Adv. P.K.R. Menon, learned senior standing counsel for the Government of India (Taxes) assisted by Adv. Jose Joseph, standing counsel for Income Tax Department and Adv. Ajay V. Anand.

3. ITA.No.212 of 2013 was admitted on 21.11.2013 and the following substantial questions of law were fo