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आयकर अपीलीय अिधकरण, ‘ए’ (cid:13)ायपीठ, चे(cid:18)ई।

IN THE INCOME TAX APPELLATE TRIBUNAL

‘A’ BENCH: CHENNAI

(cid:21)ी जॉज(cid:24) जॉज(cid:24) के , उपा(cid:26)(cid:27), एवं सु(cid:21)ी पदमावती यस, लेखा सद$ के सम(cid:27)

BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENTAND

MS. PADMAVATHY.S, ACCOUNTANT MEMBER

आयकर अपील सं./ITA No.3282/Chny/2025

िनधा(cid:24)रण वष(cid:24) /Assessment Year: 2019-20

DD 587A Vellodu Primary The Income Tax Officer,

Agricultural Co-operative Credit Vs. Ward-1,

Society, Dindigul.

A. Vellodu Post,

Dindigul – 624 307.

PAN: AABAD 1246P

(अपीलाथ(cid:7)/Appellant) ((cid:8)(cid:9)यथ(cid:7)/Respondent)

अपीलाथ( की ओर से/ Appellant by : Mr.K. Balasubramanian, C.A

*+थ( की ओर से /Respondent by : Ms. R. Kavitha, Addl. CIT

सुनवाई की तारीख/Date of Hearing : 21.01.2026

घोषणा की तारीख /Date of Pronouncement : 04.02.2026

आदेश / O R D E R

PER PADMAVATHY.S, A.M:

This appeal by the assessee is against the order of the Commissioner of

Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, (in

short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the

Act") dated 15.07.2025 for Assessment Year (AY) 2019-20.

2. The assessee is a primary agriculture co-operative credit society and

did not file the return of income during the year under consideration. Since

the assessee had deposited cash amounting to Rs. 2,31,83,000/-, the A.O

ITA No.3282/Chny/2025

DD 587 A Vellodu Primary Agricultural

Co-operative Credit Society

:- 2 -:

reopened the assessment by issue of notice u/s. 148 of the Act. The A.O

completed the assessment by making an addition u/s. 69A of the Act towards

unexplained money stating that the assessee has not furnished sufficient

details explaining the source. Aggrieved, the assessee filed further appeal

before the CIT(A). There was a delay of 181 days in filing the appeal before

the CIT(A) and the CIT(A) did not condone the delay and dismissed the

appeal in limine. The assessee is in appeal before the Tribunal against the

order of the CIT(A).

3. There is a delay of 48 days in filing the appeal before the Tribunal. The

assessee filed an affidavit along with a petition for condoning the delay

stating that the appellate order not received by the assessee only upon receipt

of the officer for recovery proceedings, the assessee came to know of the

appeal being disposed off. Having heard both the parties and perused the

material on record, we are of the view that there is a reasonable and sufficient

cause for the delay in filing the appeal before the Tribunal. Therefore

following the Hon’ble Supreme Court decision in the case of Collector, Land

Acquisition Vs. MST.Katiji & Ors., (167 ITR 471) (SC) we condone the

delay in filing the appeal and admit the appeal for adjudication.

4. We have heard the parties, and perused the material available on

record. We notice that the assessee has made submissions before the CIT(A)

with regard to the delay in filing the appeal as extracted below:

“2.2 The appellant has requested for the condonation in delay in filing of

the appeal and has submitted his reply in this regard in Form No.35 as

under:-

The assessee is a cooperative credit society and the society secretaries

are mostly appointed on the basis of promotion basically they are

ITA No.3282/Chny/2025

DD 587 A Vellodu Primary Agricultural

Co-operative Credit Society

:- 3 -:

from clerk posting, and in few cases they are only qualified with

diploma in Cooperative and the society does not have qualified

accountant to comply with accounting and Taxation Laws and

Procedures. So to oversee and verify the accounts of the society the

cooperative societies act prescribes Assistant Director of cooperative

audit to conduct the statutory cooperative audit and they, in the

course of their verification, verify the books of accounts and produce

report on such verification. Due to the lack of sufficient number of

Cooperative auditors in the Cooperative Audit Department during the

previous years there was a delay in completion and issuance of

reports to the society and al