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2025 Supreme(Online)(Mad) 63369

IN THE HIGH COURT OF JUDICATURE AT MADRAS
C.Saravanan, J
M/S.Sithamalli Primary Agricultural Co-operative Credit Society Ltd. – Appellant
Versus
The Chief Commissioner of Income Tax – Respondent


Advocates:
For the Appellants/Petitioners: Mr.Karthikaa Ashok
For the Respondents: Mr.N.Dilip Kumar Senior Standing Counsel

Table of Content
1. procedures should not inhibit entitlement to tax deductions. (Para 2)
2. details required for assessment depend on timely document submission. (Para 3)

ORDER

Mr.N.Dilip Kumar, learned Senior Standing Counsel takes notice for the respondent.

2.The petitioner is before this Court against the impugned order, dated

16.08.2024, passed by the respondent/the Chief Commissioner of Income Tax Act, 1961 , (herein after referred to as Act), whereby, the delay in filing the ITR returns under Section 119 (2)(b) of the Act has been rejected.

3.The dispute pertains to the assessment years 2018-19 to 2022-23. The due dates for filing the return of income under Section 139 of the Act for claiming deduction under Section 80P of the Act for the aforesaid assessment years are as under:-

AY Due Date
2018-19 31.10.2018
2019-20 31.09.2020
2020-21 15.02.2021
2021-22 15.03.2022
2022-23 07.11.2022

4.The impugned order has referred to Circular No.13/2023, dated

26.07.2023 in File No.173/21/2023- ITA -I. It has referred to para 6 from the above circular, which reads as under:-

“6.In the context of para-5 above, the CCsIT/DGsIT while deciding such applications for condonation of

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