BARODA DISTRICT COOPERATIVE MILK PRODUCERS UNION LIMITED,VADODARA, GUJARAT vs. ASST. COMMISSIONER OF INCOME TAX OFFICER, CIRCLE 1(1)(1), VADODARA, VADODARA, GUJARAT

ITA 417/AHD/2025Status: DisposedITAT Ahmedabad25 August 2026AY 2022-23Bench: SMT.ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND Ms.SUCHITRA R. KAMBLE (Judicial Member)17 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee was entitled to claim deduction under Section 80P(2)(d) on the gross income earned, following previous ITAT decisions. The disallowance under Section 14A was also deleted based on favorable case law.

What were the facts?

The assessee, a cooperative society, claimed deductions under Section 80P for interest and dividend income, profit on sale of seeds, and also claimed expenses not subject to disallowance under Section 14A. The Assessing Officer (AO) and Commissioner (Appeals) disallowed these claims.

What were the issues?

Whether deductions under Section 80P(2)(d) should be allowed on gross or net income, and whether disallowances under Section 14A are justified when investments are made from own funds.

Which sections of the Income-tax Act were involved?

Section 80P,Section 14A

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Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SMT.ANNAPURNA GUPTA & Ms.SUCHITRA R. KAMBLE

For Appellant: Shri Manish J. Shah, and Shri Rushin Patel, ARs, Shri B.P. Srivastava, Sr.DR
Hearing: 13/05/2025Pronounced: 08/07/2025

आदेश आदेश आदेश

PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER

All the three appeals are filed by the same assessee against separate orders of the Ld.Commissioner of Income Tax(Appeals), National Faceless Appeal Centre (NFAC), Delhi for the above three assessment years.

Since the issue involved in all these appeals , it was common ground, was identical, all the appeals were therefore, tak

The order continues below.

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