IN THE INCOME TAX APPELLATE TRIBUNAL “SMC’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos. 3127 & 3128/Bang/2025 Assessment Year: 2018-19 & 2019-20 Bhuvaneshwari Co-op. Credit Society Ltd.

Amingad ITO Tq. Hunagund, Ward 1 & TPS Vs.

Dist. Bagalkot 587112 Bagalkot Karnataka PAN NO : ADCFS2692B APPELLANT RESPONDENT Appellant by : Sri Veeranna M Murgod, A.R.

Respondent by : Sri Ganesh R Ghale, D.R.

Date of Hearing : 26.02.2026 Date of Pronouncement : 23.03.2026

O R D E R

PER KESHAV DUBEY, JUDICIAL MEMBER:

These two appeals at the instance of the assessee is directed against the orders of the ld.CIT(A)/NFAC dated 22/08/2025 vide DIN and Order No: ITBA/NFAC/S/250/2025-26/1079888099(1) for the AY 2018-19 and dated 26/08/2025 vide DIN and Order No: ITBA/NFAC/S/250/2025-26/1080023130(1) for the AY 2019-20 passed u/s. 250 of the Income Tax Act, 1961 (in short “the Act”). Since issue involved in both these appeals are common, these are clubbed together, heard together and disposed of by this common order for the sake of convenience and brevity.

2. The assessee has raised the following grounds of appeal in ITA No: 3127/BANG/2025 for the AY 2018-19-

1. The learned Commissioner of Income Tax (Appeals) order is opposed to the Facts of the case and law.

2. Because, the learned Commissioner of Income Tax (Appeals) have denied to consider the appeal on merits and failed to provide sufficient opportunity to the appellant to present the arguments in this regards, wherein the appellant has mentioned that the appellant has been allotted with another PAN with AOP status against which the appellant has filed the return of income.

3. Because, the learned lower authorities have also not provide sufficient opportunity and failed to appreciate that the appellant was been allotted another PAN with AOP Status, against which the appellant has duly filed the return of income for the relevant Assessment Year.

4. The appellant craves leave to add/ alter any of the grounds of appeal before or at the time of hearing.

3. The assessee has raised the following grounds of appeal in ITA No: 3128/BANG/2025 for the AY 2019-20: -

1. The learned Commissioner of Income Tax (Appeals) order is opposed to the Facts of the case and law.

2. Because, the learned Commissioner of Income Tax (Appeals) have denied to consider the appeal on merits and failed to provide sufficient opportunity to the appellant to present the arguments in this regard, wherein the appellant has mentioned that the appellant has been allotted with another PAN with AOP Status against which the appellant has filed the return of income.

3. Because, the learned lower authorities have also not provide sufficient opportunity and failed to appreciate that the appellant was been allotted another PAN with AOP Status, against which the appellant has duly filed the return of income for the relevant Assessment Year.

4. The appellant craves leave to add/ alter any of the grounds of appeal before or at the time of hearing.

4. Before us, at the outset the ld. A.R of the assessee vehemently submitted that there is a delay of 59 days in filing both these appeal before this Tribunal and also drew our attention on the application for condonation of delay along with an affidavit dated 23/12/2025 filed by the assessee stating the reason for the delay, which are reproduced below:-

4.1 On going through the said application as well as the affidavits filed by the assessee for both these years, we take note of the fact that delay caused in filing was due to the fact that the assessee society was busy with completion of audit for FY 2024-25 conveying the AGM. Thereafter, understating the reason for dismissal by ld. CIT(A)/NFAC, the management further delayed to decide whether the matters need to be challenged before the ITAT and once convinced the management approached the counsel in this regard to file an appeal which resulted in a delay of 59 days in both these appeals.

4.2 Having perus