YEDAPADAVU VYVASAYA SAHAKARA SANGHA NIYAMITHA,YEDAPADAVU vs. INCOME TAX OFFICER, WARD-2(2), MANGALURU
Income Tax Appellate Tribunal, “SMC” BENCH : BANGALORE
Before: SHRI PRASHANT MAHARISHI
These are two appeals filed by Yedapadavu Vyvasaya Sahakara Sangha Niyamitha (the assessee/appellant). ITA No.1919/Bang/2025 is filed for AY 2018-19 against the appellate order passed by the National Faceless Appeal Centre, Delhi (NFAC) [ld. CIT(A)] dated 30.6.2025 wherein the appeal filed by the assessee against the assessment order passed u/s. 143(3) of the Income Tax Act, 1961 [the Act] on 7.4.2021
ITA Nos.1878 & 1919/Bang/2025
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by the ITO, Ward 2(1), Mangalore was dismissed. The only reason being that the profits & gains amounting to Rs.1,31,28,960 earned by the assessee cannot be said to be derived or earned from carrying on the business of providing credit facilities to its members and further deduction u/s. 80P of the Act cannot be allowed to the assessee.
2. Similarly for AY 2020-21 the assessee is in appeal against the appellate order passed by the NFAC, Delhi dated 27.6.2025 wherein the appeal filed by the assessee against the assessment order passed u/s. 143(3) of the Act dated 20.9.2022 passed by the Assessment Unit wherein amount of Rs.30,62,453 was added to the total income of the assessee disallowing the deduction u/s. 80P(2)(d) of the Act was confirmed.
3. First we take up the appeal ITA No.1919/Bang/2025 for AY 2018-19. The facts of the case show that assessee is a co-operative society who filed its return of income on 24.10.2018 showing gross total income of Rs.36,73,878 and claimed deduction u/s. 80P of the same amount. The return was selected for limited scrutiny for verifying the investments etc. and deduction under Chapter VIA of the Act. The assessee has claimed deduction of Rs.36,73,878 u/s. 80P of the Act. It supported with the certificate issued by the