SWAMI VIVEKANANAD NAGARI SAHAKARI PATPEDHI MARYADIT,PUNE vs. ITO WARD - 12(1), PUNE, PUNE
आयकर अपीलीय अिधकरण ”बी” Ɋायपीठ पुणेमŐ।
IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCHES “B” :: PUNE
BEFORE MS.ASTHA CHANDRA, JUDICIAL MEMBER
AND DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER
आयकर अपील सं. / ITA No.1190/PUN/2025
िनधाᭅरण वषᭅ / Assessment Year: 2020-21
Swami
Vivekanand
Nagari
SahakariPatpedhiMaryadit,
412, Amit Residency,
Mehunpura, Shaniwar Petha,
Pune – 411030. Maharashtra.
V s.
The Income Tax Officer,
Ward-12(1), Pune.
PAN: AACAS8068F
Appellant/ Assessee
Respondent / Revenue
Assessee by Smt.Deepa Khare – AR
Revenue by Shri Amit Bobde –CIT(DR)
Date of hearing
12/06/2025
Date of pronouncement 18/06/2025
आदेश/ ORDER
PER DR. DIPAK P. RIPOTE, AM:
This is an appeal filed by the assessee against the order of ld.Principal Commissioner of Income Tax, Pune-4 under section 263
of the Income Tax Act, 1961 for A.Y.2020-21 dated 04.03.2025
emanating from the assessment order under section 143(3) of the Act, dated 28.09.2022. The Assessee has raised the following grounds of appeal :
ITA No.1190/PUN/2025 [A]
2
“1. The Id. PCIT erred on facts and in law in failing to consider that the Assessment Order was passed by the Id. AO after having conducted an inquiry on the deduction claimed Chapter VIA i.e. deduction u/s.
80P and 80P(2)(d).
The Id. PCIT erred on facts and in law in failing to consider THAT the Id. AO had adopted a plausible course of action in view of the prevailing law regarding deduction under Chapter VIA vis-a-vis the precedents set by the Supreme Court and High Courts passed the Assessment Order.
The Appellate craves the permission to add, amend, modify, alter, revise, substitute delete any or all grounds at the time of hearing of appeal.”
Findings & Analysis :
We have heard both the parties and perused the records. Admittedly, Assessee is a Co-operative Credit Society registered under Maharashtra Co-operative Societies Act, carrying on the business of providing credit facility to its members. Copy of the Certificate issued under Maharashtra Co-operative Societies Act, 1960 by