AHMEDNAGAR ZILLA GRAMSEVAKANCHI SAHAKARI PATSANSTHA MARYADIT,PUNE vs. ITO WARD 1, AHILYANAGAR
आयकर अपीलीय अिधकरण ”एस एम सी” Ɋायपीठ पुणेमŐ।
IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCHES “SMC” :: PUNE
BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER
AND SHRI VINAY BHAMORE, JUDICIAL MEMBER
आयकर अपील सं. / ITA No.1592/PUN/2025
िनधाᭅरण वषᭅ / Assessment Year: 2022-23
Ahmednagar
Zilla
Gramsevakanchi
Sahakari
Patsanstha Maryadit,
1, Opp.Sardar Patel Karyala,
Behind
Ketkar
Hospital,
Ahilyanagar – 414001. Maharashtra.
V s
The Income Tax Officer,
Ward-1, Ahilyanagar.
PAN: AAAAA6582G
Appellant/ Assessee
Respondent / Revenue
Assessee by Shri Payal Rathi – CA/AR
Revenue by Shri Sandeep P Sathe – JCIT(DR)
Date of hearing
17/07/2025
Date of pronouncement 21/07/2025
आदेश/ ORDER
PER DR. DIPAK P. RIPOTE, AM:
This is an appeal filed by Assessee against the order of ld.Commissioner of Income Tax(Appeal)[NFAC], passed under section 250 of the Income Tax Act, 1961 for the A.Y.2022-23 dated
06.05.2025, emanating from order u/s.143(3) of the Income Tax Act,
ITA No.1592/PUN/2025 [A]
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1961, dated 14.02.2024. The Assessee has raised following grounds of appeal :
“1. On the facts and in the prevailing circumstances of the case and in Law, Ld. Cit NFAC erred in confirming the addition made by the Ld.
Assessing Officer without appreciating the fact that interest on the deposits made by a co operative society with the co-operative Bank is eligible for deduction under section 80P of the Act. Hence, the impugned order under section 263 may please be squashed.
On the facts and in the prevailing circumstances of the case and in Law, Ld. CIT NFAC erred in confirming the addition made by the Assessing Officer without appreciating the submission made by the assessee society and the judgments of Hon'ble Juri ictional Pune ITAT. Hence, the impugned order under section 263 may please be squashed.
The Appellate craves the permission to add, amend, modify, alter, revise, substitute, delete any or all grounds of the appeal, if deemed necessary at the time of hearing of the appeal.”
Brief facts of the case :
1 As per the assessment order, the assessee is co-operative society registered under the Maharashtra state Co-operative societies Act, 1960 formed for the benefit of Gramsevak i.e.Employees of Grampanchayat and Zilha Parishad Servants in the Ahmednagar District. The members of the society are only Government servants. The Main Objective & business of Society is "Accepting deposits from members and lending money to the members of the society". The Assessee Society is providing credit facilities only to its members and interest is charged on these credit facilities/loans advances made, while the assessee has also received deposits from ITA No.1592/PUN/2025 [A]
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its members and paid interest on these deposits as per sec 35 of the Act. The Society is working as per provisions of Co-operative
Societies Act 1960 & Bye laws prescribed by Co-operative Societies
Act 1960, authenticated by District Deputy