What did the Tribunal hold?

The Tribunal held that the AO erred in applying the surcharge rate for an AOP to a co-operative society. The surcharge should be levied as applicable to co-operative societies.

The assessee, a co-operative society, challenged the surcharge rate applied by the AO. The AO had applied the surcharge rate applicable to an AOP instead of that for co-operative societies.

What were the issues?

Whether the AO correctly applied the surcharge rate applicable to co-operative societies or AOPs.

Sapthagiri Grameena Bank, Chittoor vs DCIT | ITAT Hyderabad 2026

the Act to the assessee. Thus, the ground no.1 raised by the assessee is dismissed. 17. Under ground no.2 of the appeal of the assessee, the assessee has challenged the rate of surcharge levied by the Ld. AO. The Ld. AR has submitted that the Ld. AO has applied the rate of surcharge applicable to AOP instead of co-operative societies. In the present case, there is no dispute about the fact that the assessee is a co-operative society. Accordingly, the Ld. AR is directed to levy surcharge as applicable to a co-operative society in the case of the assessee. Accordingly, ground no.2 of the appeal of the assessee is allowed. 18. In the result, the appeal of the assessee in ITA No. 2021/Hyd/2025 for the A.Y. 2023-24 is partly allowed.

ITA Nos. 1804, 2020 & 1805 /Hyd/2025 for A.Ys 2019-20, 2020-21 and 2022-23:

19.

The issues raised in these three appeals are identical to the issues raised by the assessee in ITA No.2021/Hyd/2025 for the A.Y. 2023-24. Therefore, our observations and findings recorded therein shall apply mutatis mutandis to these three appeals as well. Since we have partly allowed the appeal of the assessee in ITA No.2021/Hyd/2025 for the A.Y. 2023-24, these three appeals of the assessee for the A.Ys. 2019-20, 2020-21 and 2022-23 are also partly allowed.

20.

To sum up, all the four appeals filed by the assessee are partly allowed.

Order pronounced in the Open Court on 29th May, 2026. Sd/- Sd/- (VIJAY PAL RAO) (MADHUSUDAN SAWDIA) VICE PRESIDENT ACCOUNTANT MEMBER Hyderabad, dated 29th May, 2026. Vinodan/sps Copy to: S.No Addresses 1 Sapthagiri Grameena Bank, Head Office, Raghu Mansion, 4/1 Brodipet, Guntur 522002 Andhra Pradesh 2 Dy. CIT/ACIT, Circle 1(1) Tirupati 3 Pr. CIT – Tirupati 4 DR, ITAT Hyderabad Benches 5 Guard File By Order VADREVU Digitally signed by VADREVU PRASADA PRASADA RAO Date: 2026.05.29 RAO 14:03:15 +05'30'

SAPTHAGIRI GRAMEENA BANK,CHITTOOR vs. DCIT CIRCLE-1(1), TIRUPATI

What did the Tribunal hold?

What were the facts?

What were the issues?

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