India's ITAT rejects Section 80P deduction claim and restores TDS credit in tax appeals

The Bangalore bench of the Income Tax Appellate Tribunal (ITAT) ruled that Primary Agricultural Credit Co‑operative Society Ltd. was not entitled to a deduction under Section 80P(2)(a)(i) because it had failed to file its original return and had not obtained condonation for the delay. The Tribunal upheld the Assessing Officer’s denial and remanded the case to determine whether the income should be taxed under Section 56, in which case a deduction under Section 57 would be applicable.

The Jaipur bench of the ITAT allowed the appeal of Bhandari Bros, a commission agent, which had claimed TDS credit under Sections 194Q, 194H and 194A for FY 2022‑23. The Tribunal held that the tax had already been credited to the Government Treasury in the assessee’s PAN, and therefore the credit could not be denied merely because it was deducted under the wrong provision. It directed the Assessing Officer to grant the TDS credit claimed under Section 194Q.