Wp(Md)/22108/2025 Of R 1000 Eranyamangalam Primary v. The Chief Commissioner Of Income Tax

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 13.08.2025 CORAM: THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.(MD)Nos.22108 to 22133 & 22216 of 2025 andW.M.P.(MD)Nos.17208, 17255, 17239, 17235,17210,17212, 17240, 17249, 17257,17260, 17244, 17252, 17241, 17237, 17216, 17221,17223, 17226, 17259, 17262, 17247, 17246, 17225, 17230, 17268, 17265 & 17303 of 2025 R 1000 Eranyamangalam PrimaryAgricultural Cooperative Credit Society (PAN. ), Rep. by its Secretary, Eranyamangalam, Kulithalai, Karur District. .. Petitioner in W.P.(MD)No.22108/2025 R6104 Thannerpalli PrimaryAgricultural Cooperative Credit Society, (PAN. ), Rep. by its Secretary, Thannerpalli, Kulithalai, Karur District. .. Petitioner in W.P(MD)No.22109/2025 R 28/6013 Nangavaram Primary Agricultural Cooperative Credit Society (Pan. ) Rep. by its Secretary, Nangavaram, Kulithalai, 1/22 .. Petitioner in W.P(MD)No.22110/2025 R 4299 Thogaimalai Primary Agricultural Cooperative Credit Society (Pan. ), Rep. by its Secretary, Thogaimalai,Karur District. .. Petitioner in W.P(MD)No.22111/2025 MM 289 Thondamanginam Primary Agricultural Cooperative Credit Society (Pan. AABM1072C), Rep. by its Secretary, Thondamanginam, Kadavur, Karur District. .. Petitioner in W.P(MD)No.22112/2025 MM 383 Manavasi Primary Agricultural Co-Operative Credit Society (Pan. ), Rep by its Secretary, Renganathapuram (South), Karur District. .. Petitioner in W.P(MD)No.22113/2025R255 Chinnavalayapatti Primary Agricultural Co-Operative Credit Society Limited (Pan. ), Rep. by its Secretary, 353 Chinnavalayapatti, Aravakurichi Post, Aravakurichi Taluk,Karur. .. Petitioner in W.P(MD)No.22114/2025TY.SPL.103. Ambapur Primary Agricultural Co-Operative Credit Society Limited (Pan. ), Rep., by its Secretary, 1, Vikkramangalam Village, Ambapoor Post, Udayarpalayam Tauk,Ariyalur District. .. Petitioner in W.P(MD)No.22115/2025 2/22 MM 358 Neilthalur Primary Agricultural Cooperative Credit Society(Pan. ), Rep. by its Secretary, Neithalur, Kulithalai, Karur District. .. Petitioner in W.P(MD)No.22116/2025 R352 Thimmachipuram Primary Agricultural Cooperative Credit Society (Pan. ), Rep. by its Secretary, Thimmachipuram Post, Kulithalai, Karur District. .. Petitioner in W.P(MD)No.22117/2025 YK57T Marudhur Primary Agricultural Cooperative Credit Society (Pan. ) Rep. by its Secretary, Marudhur, Kulithalai, Karur District. .. Petitioner in W.P(MD)No.22118/2025 MM284 Nachalur Primary Agricultural Cooperative Credit Society(Pan. ), Rep. by its Secretary, Nachalur, Kulithalai Taluk, Karur District. .. Petitioner in W.P(MD)No.22119/2025MM393 Mylady Primary Agricultural Cooperative Credit Society Limited (Pan.Aabam8871f), Rep. by its Secretary, Mylady Post, Kulithalai, Karur District. .. Petitioner in W.P(MD)No.22120/2025 MM284 Nachalur Primary Agricultural Cooperative Credit Society (Pan. ), Rep. by its Secretary, Nachalur, Kulithalai Taluk, 3/22 Karur District. .. Petitioner in W.P(MD)No.22121/2025 DD 597 Kabbileyapatti Primary Agricultural Co-Operative Credit Society Limited (Pan.Aabad0331R), Rep by its Secretary, Kabbileyapatti, Thangachiyammapatti, Oddanchatram, Dindigul District. .. Petitioner in W.P(MD)No.22122/2025 R 352 Thimmachipuram Primary Agricultural Co-Operative Credit Society (PAN ), Rep. by its Secretary, Thimmachipuram Post, Kulithalai,Karur District. .. Petitioner in W.P(MD)No.22124/2025 MM284 Nachalur Primary Agricultural Cooperative Credit Society (Pan. ), Rep. by its Secretary, Nachalur, Kulithalai Taluk, 3/22 Karur District. .. Petitioner in W.P(MD)No.22121/2025 DD 597 Kabbileyapatti Primary Agricultural Co-Operative Credit Society Limited (Pan.Aabad0331R), Rep by its Secretary, Kabbileyapatti, Thangachiyammapatti, Oddanchatram, Dindigul District. .. Petitioner in W.P(MD)No.22122/2025 R 352 Thimmachipuram Primary Agricultural Co-Operative Credit Society (PAN ), Rep. by its Secretary, Thimmachipuram Post, Kulithalai,Karur District. .. Petitioner in W.P(MD)No.22124/2025 R214 Alamarathupattu Primary Agricultural Co-Operative Credit Society (Pan ), Rep. by its Secretary, K. Pichamopatti Taluk, Karur District. .. Petitioner in W.P(MD)No.22125/2025 MM 382 Kallai Primary Agricultural Co-Operative Credit Society (Pan. ), Rep. by its Secretary, Kallai, Kulithalai, Karur District. .. Petitioner in W.P(MD)No.22126/2025 MM 100 Thennilai Primary Agricultural Cooperative Credit Society (Pan. ), Rep. by its Secretary, 2/212, South Road, Thennilai Aravakurichi Taluk, Karur District. .. Petitioner in W.P(MD)No.22127/2025 4/22 MM 100 Thennilai Primary Agricultural Cooperative Credit Society (Pan. ), Rep. by its Secretary, 2/212, South Road, Thennilai, Aravakurichi Taluk, Karur District. .. Petitioner in W.P(MD)No.22128/2025 R358 Aravakurchiprimary Agricultural Cooperative Credit Society (Pan. ), Rep. by its Secretary, Tharapuram Road, Spic Nagar, Aravakurchi Village, Aravakurchi, Karur District... Petitioner in W.P(MD)No.22129/2025 MM 358 Neithalur Primary Agricultural Co-Operative Credit Society (Pan. ), Rep. by its Secretary, Neithalur, Kulithalai, Karur District... Petitioner in W.P(MD)No.22130/2025 MM 337 Panchapatti Primary Agricultural Co-Operative Credit Society (Pan. ), Rep. by its Secretary, Keelapanjapatti, Panjapatti,Karur District. .. Petitioner in W.P(MD)No.22131/2025 MM 337 Panchapatti Primary Agricultural Cooperative Credit Society(Pan. ) Rep. by its Secretary, Keelapanjapatti, Panjapatti, Karur District. .. Petitioner in W.P(MD)No.22132/2025 R7924 Krishnarayapuram Primary Agricultural Cooperative Credit Society (Pan. ), Rep. by its Secretary, Krishnarayapuram, Karur District. .. Petitioner in W.P(MD)No.22133/2025 Vs. 1. The Chief Commissioner of Income Tax,CR Building, No.2, V.P.Rathinasamy Nadar Road, Bibikulam, Madurai - 625 002. 2. The Assessment Unit,Income Tax Department, Karur.3. The Income Tax Officer,Karur. ... Respondents in all cases W.P(MD)No.22123 of 2025: D.D. 573, Devathur PrimaryAgricultural Co-operative CreditSociety Limited (PAN. ),Rep. by its secretary, Devathur post,Oddanchatram Taluk,Dindigul District. .. Petitioner Vs. 1. The Chief Commissioner of Income Tax,CR Building, No.2, V.P.Rathinasamy Nadar Road, Bibikulam, Madurai - 625 002. 2. The Assessment Unit,Income Tax Department, Dindigul. 6/22 3. The Income Tax Officer,Dindigul District. ... Respondents W.P(MD)No.22216 of 2025:A 2163, Mallayagoundenpatty Primary Agricultural Cooperative Credit Society Limited (PAN. ) Rep. by its Secretary, Mallayagoundenpatty,North Thathankulam Post,Palani, Dindigul District. .. Petitioner Vs. 1. The Chief Commissioner of Income Tax,CR Building, No.2, V.P.Rathinasamy Nadar Road, Bibikulam, Madurai - 625 002. 2. The Assessment Unit,Income Tax Department, Dindigul. 3. The Income Tax Officer,Ware No.3, 130, Railway Feeder Road,Virudhunagar- 626 001. ... Respondents Vs. 1. The Chief Commissioner of Income Tax,CR Building, No.2, V.P.Rathinasamy Nadar Road, Bibikulam, Madurai - 625 002. 2. The Assessment Unit,Income Tax Department, Dindigul. 6/22 3. The Income Tax Officer,Dindigul District. ... Respondents W.P(MD)No.22216 of 2025:A 2163, Mallayagoundenpatty Primary Agricultural Cooperative Credit Society Limited (PAN. ) Rep. by its Secretary, Mallayagoundenpatty,North Thathankulam Post,Palani, Dindigul District. .. Petitioner Vs. 1. The Chief Commissioner of Income Tax,CR Building, No.2, V.P.Rathinasamy Nadar Road, Bibikulam, Madurai - 625 002. 2. The Assessment Unit,Income Tax Department, Dindigul. 3. The Income Tax Officer,Ware No.3, 130, Railway Feeder Road,Virudhunagar- 626 001. ... Respondents PRAYER in W.P.(MD)No.22108/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/1325/CC/MDU/TECH/2023-24 dated 26.11.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021-2022 for the petitioner society. 7/22 PRAYER in W.P.(MD)No.22109/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/842/CC/MDU/TECH/2023-24 dated 10.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021-2022 for the petitioner society. PRAYER in W.P.(MD)No.22110/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/846/CC/MDU/TECH/2023-24 dated 05.11.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021-2022 for the petitioner society. PRAYER in W.P.(MD)No.22111/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/1294/CC/MDU/TECH/2023-24 dated 30.07.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021-2022 for the petitioner society. PRAYER in W.P.(MD)No.22112/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call 8/22 for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/1423/CC/MDU/TECH/2023-24 dated 27.06.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020-2021 for the petitioner society. PRAYER in W.P.(MD)No.22113/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/822/CC/MDU/TECH/2023-24 dated 05.11.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021-2022 for the petitioner society. PRAYER in W.P.(MD)No.22114/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/1169/CC/MDU/TECH/2023-24 dated 06.02.2025 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020-2021 for the petitioner society. PRAYER in W.P.(MD)No.22114/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/1169/CC/MDU/TECH/2023-24 dated 06.02.2025 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020-2021 for the petitioner society. PRAYER in W.P.(MD)No.22115/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/576/CC/MDU/TECH/2023-24 dated 06.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income 9/22 tax return for the assessment year 2022-2023 for the petitioner society. PRAYER in W.P.(MD)No.22116/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/474/CC/MDU/TECH/2023-24 dated 06.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021-2022 for the petitioner society. PRAYER in W.P.(MD)No.22117/2025Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned Order passed by the 1st respondent in C.No. 2115/859/CC/MDU/TECH/2023-24 dated 10.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2022-2023 for the petitioner society. PRAYER in W.P.(MD)No.22118/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in Order in C.No. 2115/1343/CC/MDU/TECH/2023-24 dated 10.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021- 2022 for the petitioner society. 10/22 PRAYER in W.P.(MD)No.22119/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No. 2115/897/CC/MDU/TECH/2023-24 dated 16.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021-2022 for the petitioner society. PRAYER in W.P.(MD)No.22120/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No.2115/850/CC/MDU/TECH/2023-24 dated 18.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021- 2022for the petitioner society. PRAYER in W.P.(MD)No.22121/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus,to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No.2115/898/CC/MDU/TECH/2023-24 dated 16.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2022-2023 for the petitioner society. PRAYER in W.P.(MD)No.22122/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in 11/22 PRAYER in W.P.(MD)No.22121/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus,to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No.2115/898/CC/MDU/TECH/2023-24 dated 16.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2022-2023 for the petitioner society. PRAYER in W.P.(MD)No.22122/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in 11/22 C.No. 1012/1169/CC/MDU/TECH/2023-24 dated 16.01.2025 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2018- 2019 for the petitioner society. PRAYER in W.P.(MD)No.22123/2025: Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No.1012/381/CC/MDU/TECH/2023-24 dated 30.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2018- 2019 for the petitioner society. PRAYER in W.P.(MD)No.22124/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No. 2115/857/CC/MDU/TECH/2023-24 dated 10.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020- 2021 for the petitioner society. PRAYER in W.P.(MD)No.22125/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No.2115/839/CC/MDU/TECH/2023-24 dated 05.11.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2022- 2023 for the petitioner society. 12/22 PRAYER in W.P.(MD)No.22126/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No. 2115/1338/CC/MDU/TECH/2023-24 dated 04.07.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020- 2021 for the petitioner society. PRAYER in W.P.(MD)No.22127/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No. 2115/1840/CC/MDU/TECH/2023-24 dated 20.08.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021- 2022 for the petitioner society. PRAYER in W.P.(MD)No.22128/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No. 2115/1839/CC/MDU/TECH/2023-24 dated 08.08.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020- 2021 for the petitioner society. PRAYER in W.P.(MD)No.22129/2025:Writ Petition filed under Article 226 of 13/22 PRAYER in W.P.(MD)No.22128/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No. 2115/1839/CC/MDU/TECH/2023-24 dated 08.08.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020- 2021 for the petitioner society. PRAYER in W.P.(MD)No.22129/2025:Writ Petition filed under Article 226 of 13/22 the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No. 2115/1280/CC/MDU/TECH/2023-24 dated 31.07.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020- 2021 for the petitioner society. PRAYER in W.P.(MD)No.22130/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No.2115/475/CC/MDU/TECH/2023-24 dated 06.09.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2022- 2023 for the petitioner society. PRAYER in W.P.(MD)No.22131/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in Order in Order in C.No.2115/1359/CC/MDU/TECH/2023-24 dated 05.07.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2021- 2022 for the petitioner society PRAYER in W.P.(MD)No.22132/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in 14/22 Order in Order in C.No.2115/1358/CC/MDU/TECH/2023-24 dated 05.07.2024 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2020- 2021 for the petitioner society PRAYER in W.P.(MD)No.22133/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No. 2115/827/CC/MDU/TECH/2023-24 dated 06.02.2025 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2022- 2023 for the petitioner society. PRAYER in W.P.(MD)No.22216/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No.2115/689/CC/MDU/TECH/2023-24 dated 12.09.2025 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2018- 2019 for the petitioner society. For Petitioner in all W.Ps : Mr.T.Veldurai For Respondents in all W.Ps: Mr.N.Dilip Kumar Senior Standing Counsel ***** 15/22 COMMON ORDER By this common order, all these Writ Petitions are taken up for disposal. PRAYER in W.P.(MD)No.22216/2025:Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records in pursuant to the Impugned order passed by the 1[st] respondent in C.No.2115/689/CC/MDU/TECH/2023-24 dated 12.09.2025 quash the same and consequently direct the 1st respondent to condone the delay in filing the income tax return for the assessment year 2018- 2019 for the petitioner society. For Petitioner in all W.Ps : Mr.T.Veldurai For Respondents in all W.Ps: Mr.N.Dilip Kumar Senior Standing Counsel ***** 15/22 COMMON ORDER By this common order, all these Writ Petitions are taken up for disposal. 2. In these writ petitions, the petitioners have challenged the impugned orders as detailed in Column No.7 for the respective assessment years as detailed in Column.2. By the impugned order, the application filed for condonation of delay in filing the return for claiming exemption/deduction under 80(P) of the Income Tax Act, 1961, has been rejected. Admittedly, the returns were not filed by the due date as per Section 139(1) of the Income Tax Act, 1961. All the petitioners in these writ petitions are Primary Agricultural Cooperative Credit Society. The denial of the benefit of exempt deduction under Section 80P(2)(d) of the Act is being denied only on the ground that no returns were filed by the petitioners within the due date as detailed in Column.4 to the above table. This Court has taken a categorical stand in several cases that if the benefit of deduction is otherwise legitimately available, the delay in filing the return of income should not come in the way of extension of the deduction. Therefore, the impugned order seeking to reject the application filed for condonation of delay in filing the return deserves to be interfered with. 18/22 3. The Writ Petition is however stoutly opposed by the learned counsel for the respondent on the ground that there is no scope for interfering with the impugned order of the respondent. It is submitted that despite the statutory audit report being furnished to the petitioners, there is a delay in filing the application for condonation of delay. It is submitted that this is a recurring issue and every year there is a delay on the part of the petitioners in claiming such filing the returns in time. 4. The Hon'ble Supreme Court in Commissioner Of Sales Tax, State of Uttar Pradesh v. Auriaya Chamber of Commerce reported in1986(25)ELT 867 has held that the procedures are hand-maids of justice and not the mistress of law. Applying the above ratio, I am of the view that the impugned orders are liable to be quashed with a consequential direction to the concerned assessing officer to finalise the assessment by extending the benefit of Section 80P(2d) of the Income Tax Act. Since the petitioners have delayed in filing the returns in time, the petitioners shall also pay a token amount of Rs.5,000/- each, to the Adyar Cancer Institute (WIA), East Canal Bank Road, Adyar, Chennai, within a period of 30 days from the date of receipt of a copy of this order. Subject to the 19/22 petitioners complying the same, the second respondent shall pass the fresh assessment order by extending the benefit of Section 80P of the Income Tax Act, if the petitioners are otherwise entitled to the relief but for the delay in filing the returns in time. 5. All these Writ Petitions are disposed of. No Costs. Consequently, connected miscellaneous petitions are closed. Index : Yes / No13.08.2025Internet : Yes / NoPJLTo1. The Chief Commissioner of Income Tax,CR Building, No.2, V.P.Rathinasamy Nadar Road, Bibikulam, Madurai - 625 002.2. The Assessment Unit,Income Tax Department, Karur.3. The Income Tax Officer,Karur. 20/22 4. The Assessment Unit,Income Tax Department, Dindigul. 5. The Income Tax Officer,Dindigul District. 6. The Income Tax Officer,Ware No.3, 130, Railway Feeder Road,Virudhunagar- 626 001. 21/22 22/22 https://www.mhc.tn.gov.in/judis C.SARAVANAN, J. PJL 5. All these Writ Petitions are disposed of. No Costs. Consequently, connected miscellaneous petitions are closed. Index : Yes / No13.08.2025Internet : Yes / NoPJLTo1. The Chief Commissioner of Income Tax,CR Building, No.2, V.P.Rathinasamy Nadar Road, Bibikulam, Madurai - 625 002.2. The Assessment Unit,Income Tax Department, Karur.3. The Income Tax Officer,Karur. 20/22 4. The Assessment Unit,Income Tax Department, Dindigul. 5. The Income Tax Officer,Dindigul District. 6. The Income Tax Officer,Ware No.3, 130, Railway Feeder Road,Virudhunagar- 626 001. 21/22 22/22 https://www.mhc.tn.gov.in/judis C.SARAVANAN, J. PJL W.P.(MD) Nos.22108 to 22133 &22216 of 2025 13.08.2025