INCOME TAX OFFICER, WARD-8(3), PUNE, PUNE vs. SHRI KSHETRA BHIMASHANKAR GRAMIN BIGAR SHETI SAHAKARI PATSANSTHA MARYADIT, PUNE
आयकर अपीलीय अिधकरण ”A” ायपीठ पुणे म।
IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCHES “A” :: PUNE
BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER
AND SHRI VINAY BHAMORE, JUDICIAL MEMBER
आयकर अपील सं. /ITA No.473/PUN/2025
िनधारण वष / Assessment Year: 2018-19
Income Tax Officer,
Ward-8(3), Pune
Vs
Shri Kshetra Bhimashankar
Gramin Bigar Sheti Sahakari
Patsanstha Maryadit
Ganesh Nagar, Road No.7,
Kiran Sagar Heights,
Bopkhel, Pune-411031,
Maharashtra
PAN: AAQAS0672R
Appellant/ Revenue
Respondent/ Assessee
Assessee by None
Revenue by Shri Rajesh Gawali - (DR)
Date of hearing
26/08/2025
Date of pronouncement 28/08/2025
आदेश/ ORDER
PER DR. DIPAK P. RIPOTE, AM:
This is an Appeal filed by the Revenue against the Order of the Commissioner of Income tax (appeal) (NFAC) under section 250 of the Income Tax Act, 1961 for A.Y.2018-19 dated 17/12/2024
emanating from Assessment Order u/s.147 r.w.s144 r.w.s144B dated
22/02/2023. 2
2. Findings & Analysis :
We have heard Ld.DR and perused the records. In this case, no one appeared on behalf of the assessee. This is the appeal filed by the Revenue against the Order of the Commissioner of income Tax
(Appeal) (NFAC) dated 17/12/2024 for AY 2018-19. Assessee is a cooperative credit society registered under Maharashtra Cooperative
Societies Act . It is in the business of providing credit facility to its members. In this case, the ITO received information from the INSIGHT portal of the Income Tax Department that Assessee has deposited Rs.1,00,43,800/- in cash in current account and has done cash withdrawal of Rs.6,05,000/-. The Assessing Officer also received information that Assessee has not filed return of Income.
Based on the information, the Assessing Officer issued notice u/s.
148 of the Income Tax Act. The Assessee failed to file any reply to the various notices issued by the Assessing Officer. Then the Assessing Officer (AO) issued a final show cause notice. The Assessee failed to comply it. Assessing Officer passed an order u/s.
144 of the Act. The AO assessed total income of the assessee at Rs.1,06,48,800/-. Thus, the AO added both withdrawals and deposits.
Aggrieved by the Assessment Order, the Assessee filed an appeal before the Commissioner of Income Tax (appeal). Assessee made elaborate submission before the Commissioner of Income Tax (appeal) which has been reproduced by Commissioner of Income Tax (appeal) in the order. Assessee also filed copy of Registration certificate. The Assessee explained that the cash deposits pertains 3 to the small amounts deposited by its members in their respective accounts maintained with the Assessee Co-operative Society . The assessee then deposited these amounts in its account. Therefore, the Assessee submitted before the Commissioner of Income Tax (appeal) that cash deposits are duly explained. Assessee filed copy of Cash Book, Bank book, ledger. Assessee also submitted that its Books of Accounts have been audited and the Audit Report dated 31/07/2018 has been duly submitted to the Dy.