RIDDHI SIDDHI MAHILA NAGARI CO-OP CREDIT SOCIETY LTD, KARAD,KARAD vs. CIT (APPEALS), DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCH “B”, PUNE

BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER
AND SHRI VINAY BHAMORE, JUDICIAL MEMBER

आयकर अपील सं. / ITA No.2216/PUN/2025
िनधाᭅरण वषᭅ / Assessment Year : 2019-20

Riddhi Siddhi Mahila Nagari
Co-op. Credit Society Ltd.,
Palkar House, 157, Guruwar
Peth, Shri Vitthal Chouk,
Karad- 415110. PAN : AACAR0958D
Vs. Assessment
Unit,
Income Tax Department.
Appellant

Respondent

आदेश / ORDER

PER VINAY BHAMORE, JM:

This appeal filed by the assessee is directed against the order dated 28.08.2025 passed by Ld. CIT(A)/NFAC for the assessment year 2019-20. 2. Facts of the case, in brief, are that the assessee is a primary credit co-operative society engaged in the business of providing credit facilities to its members and also in accepting deposits from them. On the basis of information that the assessee has made one time deposit of Rs.5,95,522/- and TDS of more than Rs.7,72,686/-
Assessee by : Shri Vijaykumar N. Kashirsagar
Revenue by : Shri Vinod Pawar (Virtual)

Date of hearing
: 28.10.2025
Date of pronouncement : 19.11.2025
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was deducted u/s 194A of the Act on the PAN of the assessee and still assessee has not furnished its return of income for the period under consideration, the case of the assessee was reopened and notice u/s 148 was issued to the assessee after necessary compliance and approvals. Subsequently, other statutory notices u/s 142(1) and 143(2) were issued to the assessee. The assessee in compliance to above said notice u/s 148 furnished its return of income by claiming deduction u/s 80P(2)(c)(ii) of Rs.50,000/- & u/s 80P(2)(d) of Rs.17,86,296/- of the Act amounting in all to Rs.18,36,296/-.
During the course of assessment proceedings, the assessee furnished balance-sheet and other financials, details of bank accounts held by the assessee, bank statement of all the banks, details of investment made by the assessee society with other cooperative banks, details of secured and unsecured loan taken and repaid during the year and details of income from other sources i.e. interest from other cooperative banks and details of interest income on loans and advances from members and also details of interest income received on fixed deposit from other cooperative banks and details of interest paid on deposits received from members of the society and also the details of interest paid to other banks on outstanding loans were 3
furnished by the assessee. However, the Assessing Officer was not satisfied with the reply and information furnished by the assessee since he was of the opinion that the assessee failed to furnish party- wise details of cash receipts/ deposit from the members and therefore treated the whole of the deposit of Rs.7,81,16,000/- in the bank account as unexplained cash credit and also treated the interest income received from PALKAR’s as undisclosed interest income and also disallowed the deduction claimed under section 80P(2)(c)
& (d) of the Act amounting in all to Rs.18,36,296/- and added to the income of the assessee, since in the light of section 80AC of the Act, return of income was not furnished u/s 139(1) of the Act.
Accordingly, vide order dated 28.07.2023 the Assessing Officer completed the assessment u/s 147 r.w.s. 144B of the Act by determining total income at Rs.8,07,24,982/- as against Nil income returned by the assessee in the return furnished in response to notice u/s 148 of the Act.
3. Being aggrieved with the above action of the Assessing
Officer, the assessee co-operative society preferred an appeal before
Ld. CIT(A)/NFAC. Since the assessee remained absent, vide order
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dated 28.08.2025, Ld. CIT(A)/NFAC dismissed the appeal filed by the assessee.
4. It is the above order against which the assessee is in appeal before this Tribunal.
5. Ld. AR appearing from the side of the assessee submitted before us that the order passed by Ld. CIT(A)/NFAC is unjustified.
Ld. AR submitted before us that each and every detail required by the Assessing Officer was furnished before him and it was grave error on the part of the Assessing Officer to treat the whole of the receipts of Rs.7,81,16,000/- in its bank accounts as income of the assessee since the same was the regular receipt pertaining to regular business transactions of the assessee credit co-operative society with their members, the interest income of Rs.7,72,686/- was already included in the income disclosed by the assessee and the interest income received from investments made with other cooperative banks was deductible u/s 80P(2)(d) of the Act. Ld. AR further submitted that the accounts of the assessee credit co-operative society were regularly maintained and same were produced before the