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2023 (7) TMI 1161 - ITAT PANAJIDeduction u/s 80P(2)(i)(a) denied - treating the assessee as a cooperative bank than a “cooperative society” u/s.2(19) - HELD THAT:- We find no merit in the Revenue’s instant arguments seeking to invoke sec.80P(iv) of the Act in light of case of Mavilayi Service Cooperative Bank Ltd [2021 (1) TMI 488 - SUPREME COURT] holding that an assessee’s status has to be seen as per it’s registration and nature of membership hardly forms the eligibility criteria to deny the impugned deduction. We accept the assessee’s instant sole substantive grievance accordingly. Condonation of 1806 days delay as attributable to various communication gaps and other miscellaneous reasons - Hon’ble apex court’s landmark decision Collector, Land Acquisition vs., MST Katiji [1987 (2) TMI 61 - SUPREME COURT] has settled the law long back that all such technical aspects must make way for the cause of substantial justice. We, therefore, condone the impugned delay.
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