Summary
- The ITAT Mumbai has ruled that the Premier Co-operative Credit Society Ltd. cannot be denied a deduction under Section 80P due to late filing of its return before April 1, 2021.
- The Tribunal emphasized that the relevant amendments to Section 143(1)(a) allowing such disallowances only came into effect from April 1, 2021, making the prior adjustments invalid.
- The Revenue's argument for disallowance based on an "incorrect claim" was rejected as it did not meet the statutory definition under Section 143(1).
- This decision reinforces the importance of statutory authority in tax deductions and could influence future assessments involving late returns.
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