SHREENATH MHASKOBA CREDIT CO-OP. SOCIETY LTD.,PUNE vs. THE PCIT, PUNE-4, PUNE

ITA 488/PUN/2025Status: DisposedITAT Pune17 June 2025AY 2020-21Bench: SHRI R. K. PANDA (Vice President), MS ASTHA CHANDRA (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer took a plausible view after considering the assessee's reply and relevant case laws. Therefore, the PCIT's assumption of jurisdiction under Section 263 was not justified.

What were the facts?

The assessee, a co-operative credit society, claimed deduction under Section 80P(2)(a)(i) for interest income earned on investments. The PCIT invoked Section 263, holding the Assessing Officer's order allowing the deduction as erroneous and prejudicial to revenue.

What were the issues?

Whether the PCIT was justified in invoking Section 263 to revise an order where the AO had taken a plausible view on the allowability of deduction under Section 80P, even if it might be prejudicial to revenue.

Which sections of the Income-tax Act were involved?

Section 80P(2)(a)(i),Section 80P(2)(d),Section 263,Section 56,Section 143(3),Section 144B

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(3)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI R. K. PANDA & MS ASTHA CHANDRA

For Appellant: Shri Sanjay Suryawanshi
For Respondent: Shri Vishwas S. Mundhe

PER R. K. PANDA, VP :

This appeal filed by the assessee is directed against the order dated 06.02.2025 passed u/s 263 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Ld. PCIT, Pune-4, relating to assessment year 2020-21. 2. Although a number of grounds have been raised by the assessee, however, these all relate to the order of the Ld. PCIT in setting aside the order passed by the Assessing Officer u/s 143(3) of the Act by invoking the provisions of section 263 of the Act.

2

3.

Facts of the case, in brief, are that the assessee is a Co-operative Credit Society registered under the Maharashtra Co-operative Society Act, 1960 and carrying on business of provi

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 80P(2)(a)(i)

All 2,347 judgments and leading authorities on Section 80P(2)(a)(i) →

Recent GST High Court judgments

Search GST case law →