DY. COMMISSIONER OF INCOME TAX, CIR - 2(1)(1), SURAT, SURAT vs. SHREE SAYAN VIBHAG SAHAKARI KHAND UDYOG MANDLI LTD, SURAT

ITA 908/SRT/2025Status: DisposedITAT Surat27 February 2026AY 2011-12Bench: DR. B.R.R. KUMAR, VICE-PRESIDENT Ms SUCHITRA KAMBLE (Judicial Member)6 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal observed that the excess payment for sugarcane was made to members and rightly distributed. The CIT(A)'s deletion of the addition regarding these payments was upheld. Consequently, the Revenue's appeals were dismissed.

What were the facts?

The Revenue appealed the deletion of additions made by the Assessing Officer (AO) concerning sugarcane purchase price, funds received under various schemes, and denial of deduction under Section 80P(2)(d). The assessee, a cooperative society, had its assessment completed under Section 143(3). The CIT(A) had partly allowed the assessee's appeal.

What were the issues?

Whether excess payments for sugarcane to members and interest income earned from a cooperative bank are eligible for deduction under Section 80P(2)(d), and if additions made by the AO regarding various funds were justified.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 37(1),Section 80P(2)(d),Section 155,Section 145A

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Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: DR. B.R.R. KUMAR, VICE-Ms SUCHITRA KAMBLE

For Appellant: Shri Mukesh Jain, CIT(DR)
For Respondent: Shri Akshay M Modi, AR
Hearing: 22.01.2026Pronounced: 27.02.2026

PER SUCHITRA KAMBLE, JUDICIAL MEMBER:

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The captioned two appeal have been filed at the instance of the Assessee against the separate order dated 17.06.2025 & 18.06.2025 passed by the National Faceless Appeal Centre(NFAC)/CIT(A), arising in the matter of assessment order passed under s. 143(3) of the Income Tax Act, 1961 (here-in- after referred to as "the Act") relevant to the Assessment Years 2011-12 & 2014-

15.

Since the issues raised in these two appeal are identical, we are extracting the ground of appeal raised in ITA No.908/Srt/2025 for the purpose of adjudication.

ITA No.908/Srt/2025 for AY 2011-12

2.

The Revenue has

The order continues below.

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