BSNL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LIMITED ,HUBBALLI vs. PR. CIT, HUBBALLI , HUBBALLI

ITA 1108/BANG/2025Status: DisposedITAT Bangalore30 January 2026AY 2020-2129 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found that the Assessing Officer (AO) had conducted proper inquiries and applied his mind before passing the assessment order. It held that when two plausible views are possible, and the AO has adopted one, the PCIT cannot invoke Section 263 merely because he disagrees with the AO's view. The Tribunal distinguished the reliance placed on the Totgars Co-operative Sale Society Ltd. case by the PCIT.

What were the facts?

The assessee, a co-operative society, claimed deduction under Section 80P on its entire income, resulting in a declared income of 'Nil' for AY 2020-21. The Principal Commissioner of Income Tax (PCIT) invoked Section 263, holding the assessment order erroneous and prejudicial to the revenue, specifically regarding the deductibility of interest income.

What were the issues?

Whether the PCIT was justified in invoking Section 263 powers when the AO's order was based on a plausible view after due inquiry, and whether interest income from co-operative banks and commercial banks was eligible for deduction under Section 80P.

Which sections of the Income-tax Act were involved?

Section 263,Section 80P,Section 56,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ABENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

Hearing: 15.12.2025Pronounced: 30.01.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. PCIT, Hubli dated 23.03.2025 vide DIN & Order No. ITBA/REV/F/REV5/2024-25/1074892709(1) passed u/s 263 of the Income Tax Act, 1961 (in short “The Act”) for the Assessment Year 2020-21. 2. The assessee has raised the following grounds of appeal:

1.

The order of revision passed by the learned Principal Commissioner of Income Tax, Hubballi under Section 263 of the Act dated 23/03/2025, in so far as it is against the Appellant is opposed to law, weight

The order continues below.

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