Bengal Immunity Company Limited v. State of Bihar

2 SCR 603Reported decision1955#1511 most cited

What is Bengal Immunity Company Limited v. State of Bihar authority for?

Even when the language of a statutory section is clear and unambiguous, other parts of the statute, while not controlling its interpretation, can prima facie furnish a clue as to the section's meaning and purpose.

75

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

Bengal Immunity Company Limited v. State of Bihar · statutory interpretation · clear and unambiguous language · meaning and purpose of section · parts of statute as clue · Section 2(19) · Section 80P · co-operative society · 1955 SCR 603

Sections most often in play

Section 80P(4)Section 80P(2)(d)Section 143(3)Section 80P(2)(a)(i)Section 80PSection 2(19)Section 56Section 250

Issues it is cited on

section 80p(2)(b)section 22(1)(b)section 80(p)(4)section 52section 22(1)section 5(b)section 80p(1)section 80(p)(2)section 2(19)section 153a proceedingssection 71tax benefit

Judgments citing Bengal Immunity Company Limited v. State of Bihar

AURANGABAD DIVISION LIFE INSURANCE EMPLOYEES CO-OP CREDIT SOCIETY LTD,AURANBAD vs. ITO, WARD-1(1), AURANGABAD, AURANGABAD

In the result, appeal of the assessee is allowed

ITA 3175/PUN/2025[2020-21]Status: DisposedITAT Pune10 Feb 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3175/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Aurangabad Divison Life V The Income Tax Officer, Insurance Employees Co-Op S Ward-1(1), Aurangabad. Credit Society Ltd., 11, Jeevan Prakash, Lic Office Building Adalat Road, Kranti Chowk, Aurangabad -431005 Pan: Aaaaa2245A Appellant/ Assessee Respondent /Revenue Assessee By Ca Payal Rathi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 09/02/2026 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 24.09.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Income Tax Act, 1961

Section 143(3)Section 144BSection 250Section 56Section 66Section 80PSection 80P(2)(a)

…s of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section(vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State for the registratio…

INCOME TAX OFFICER WARD 1 SATARA, SATARA vs. KARAD PATAN TALUKA PRATHMIK SHIKSHAK SAHAKARI SOCIETY LIMITEDTY , KARAD

In the result, Revenue’s Appeal is dismissed

ITA 2289/PUN/2025[2020]Status: DisposedITAT Pune23 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2289/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Income Tax Officer, V Karad Patan Taluka Prathmik Ward-1, Satara. S Shikshak Sahakari Society Limited, 190 B Shaniwar Peth, Opp.Shivneri Lodge, Karad, Satara – 415110 Pan: Aaaak0559R Appellant / Assessee Respondent / Revenue Assessee By Shri Satish U Nade Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated

Section 143(3)Section 144BSection 250Section 56Section 57Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…hen the language of the section is clear and unambiguous but, being part of 8 ITA No.2289/PUN/2025 [A] the statute, it prima facie furnishes some clue as to the meaning and purpose of the section(vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State for the registrati…

INCOME TAX OFFICER WARD-2, AHMEDNAGAR, AHAMEDNAGAR vs. KANIFNATH GRMAIN BIGAR SHETI SAHAKARIPATSANSTHA MARYADIT, , MALDAD

In the result, Revenue’s Appeal is dismissed

ITA 2271/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…ds of a section particularly when the language of the section is clear and unambiguous but,being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section(vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered eitherunder the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State forthe registration…

INCOME TAX OFFICER WARD-2, AHMEDNAGAR, AHMEDNAGAR vs. KANIFNATH GRMAIN BIGAR SHETI SAHAKARI, MALDAD SANGAMNER

In the result, Revenue’s Appeal is dismissed

ITA 2270/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…ds of a section particularly when the language of the section is clear and unambiguous but,being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section(vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered eitherunder the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State forthe registration…

BOMBAY MERCANTILE CO-OP BANK LTD EMPLOYEES CO-OP CREDIT SOCIETY LTD,MUMBAI vs. ITO-17(1)(3), MUMBAI

ITA 6453/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Dec 2025AY 2013-14

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Vijay JoshiFor Respondent: Shri Leyaqat Ali Aafaqui
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co- operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co- operative Societies Act, 1912 or under any other law for the time being in force in any State for the registrat…

BOMBAY MERCANTILE CO-OP BANK LTD EMPOYEES CO-OP CREDIT SOCIETY LTD,MUMBAI vs. ITO-17(1)(3), MUMBAI

ITA 6452/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Dec 2025AY 2014-15
For Appellant: Shri Vijay JoshiFor Respondent: Shri Leyaqat Ali Aafaqui
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co- operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co- operative Societies Act, 1912 or under any other law for the time being in force in any State for the registrat…

AVINISSERY SERVICE CO-OPERATIVE BANK LTD,THRISSUR vs. THE INCOME TAX OFFICER WARD 2(1),THRISSUR, THRISSUR

ITA 569/COCH/2025[2016-17]Status: DisposedITAT Cochin27 Oct 2025AY 2016-17
Section 143(3)Section 250Section 5Section 80Section 80P

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])."* - *28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A cooperative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Cooperative Societies Act, 1912 or under any other law for the time being in force in any State for the registrat…

SHRI MAHAVEER CO-OPERATIVE CREDIT SOCIETY LTD,ALAGUR vs. INCOME TAX OFFICER, ALAGUR

ITA 6/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Jul 2025AY 2016-17

Bench: Shri Prashant Maharishi

Section 143(2)Section 143(3)Section 18Section 40Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co- operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State for the registrati…

GOLD COIN APARTMENTS CO OPERATIVE HOUSING SOCIETY LTD ,MUMBAI vs. ITO WARD 22(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 3185/MUM/2025[2021-22]Status: DisposedITAT Mumbai25 Jun 2025AY 2021-22

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Vidyadhar KhandekarFor Respondent: Shri Asif Karmal
Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State for the registratio…

PARSI SALSETTE BLDG NO. 1 CHS LIMITED ,MUMBAI vs. INCOME TAX OFFICER 24(3)(1), MUMBAI

Accordingly, Ground No. II raised by the Assessee is allowed and as a result, Ground No

ITA 1734/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 May 2025AY 2021-22

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Haridas BhatFor Respondent: Shri Akhtar Hussain Ansari
Section 143(1)Section 143(3)Section 80Section 80PSection 80P(2)(d)Section 80P(4)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co- operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co- operative Societies Act, 1912 or under any other law for the time being in force in any State for the registrat…

KUNDALIKA NAGARI SAHAKARI PATSANSTHA MARYADIT,ROHA vs. ITO, WARD 1, PANVEL, PANVEL

In the result, appeal of the assessee is allowed

ITA 790/PUN/2025[2020-21]Status: DisposedITAT Pune22 May 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.790/Pun/2025 िनधा"रण वष" / Assessment Year: 2020-21 Kundalika Nagari Sahakari V The Income Tax Officer, Patsanstha Maryadit, S Ward-1, Panvel. Ground Floor, Varun Apartment, Near Bhate Vachanalaya, Sonar Ali, Roha – 402109. Maharashtra. Pan: Aacak6478R Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Madhan Thirmanpallil – Addl.Cit(Dr) – Virtual Hearing. Date Of Hearing 13/05/2025 Date Of Pronouncement 22/05/2025

Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…s of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section(vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." ITA No.790/PUN/2025 [A] 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any…

INCOME TAX OFFICER, WARD-8(3), PUNE, PUNE vs. M/S. TATA MOTORS KARMACHARI SAHAKARI PATPEDHI LIMITED, PUNE

In the result, appeal of the Revenue is dismissed

ITA 2529/PUN/2024[2017-18]Status: DisposedITAT Pune08 May 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2529/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 The Income Tax Officer, V Tata Motors Karmachari Ward-8(3), Pune. S. Sahakari Patpedhi, H 5 3Rd Floor, C/O.Tata Motors, Pune City, Pune – 411018. Pan: Aabat7682B Appellant/ Revenue Respondent / Assessee Assessee By Shri Sanket Joshi – Ar Revenue By Shri Abhinay Kumbhar – Cit(Dr) Date Of Hearing 06/05/2025 Date Of Pronouncement 08/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 04.10.2024 For The A.Y.2017-18. The Revenue Has Raised The Following Grounds Of Appeal : “1. On The Facts & Circumstances Of The Case & In Law, The Learned Cit(A) Has Erred In Deleting The Disallowance Made By The Assessing Officer Of The Deduction Of Rs. 6,18,57,845/- Claimed Under Section Bop Of The Income-Tax Act, 1961 Being Interest Earned From The Investments

Section 250Section 56Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…s of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section(vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State for the registratio…

MR. JOY BAJAJ S/O SHYAM SUNDAR BAJAJ, vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

The appeal is allowed

ITA/88/2020HC Rajasthan11 Mar 2025

Bench: AVNEESH JHINGAN,MANEESH SHARMA

Section 14Section 143(3)Section 56Section 56(2)Section 56(2)(vii)

…[2025:RJ-JP:11201-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Income Tax Appeal No. 88/2020 Mr. Joy Bajaj S/o Shyam Sundar Bajaj, Aged About 35 Years, R/o 1/567 Vidyadhar Nagar, Jaipur. ----Appellant Versus The Assistant Commissioner Of Income Tax, Ward 4(2), Jaipur. ----Respondent For Appellant(s) : Mr. Sandeep Taneja with Mr. Aditya Sharma For Respondent(s) : Mr. Sandeep Pathak with Mr. Palash Gupta HON'BLE MR. JUSTICE AVNEESH JHINGAN HON'BLE MR. JUSTICE MANEESH SHARMA Order 11/03/2025 AVNEESH JHINGAN, J:- 1. This appeal is filed against the order of Income Tax Appellate Tribunal (…

MURUDE SAHAKARI PATSANSTHA MARYADIT ,MUMBAI vs. ITO, WARD-22(2)(1), MUMBAI

The Appeal is allowed

ITA 901/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Sept 2024AY 2018-19

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dharan GandhiFor Respondent: Shri Himanshu Sharma
Section 143Section 143(3)Section 5Section 80Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co- operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co- operative Societies Act, 1912 or under any other law for the time being in force in any State for the registrat…

DTPS EMPLOYEES CO-OP CREDIT SOCIETY LIMITED DAHANU,DAHANU vs. JURISDICTION WARD 1, PALGHAR, PALGHAR

ITA 1884/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Sept 2024AY 2018-19
Section 143(3)Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co- operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co- operative Societies Act, 1912 or under any other law for the time being in force in any State for the registration…

INCOME TAX OFFICER, ASHER IT PARK, WAGLE ESTATE, THANE vs. THANE JILLHA PRATHAMIK SIKSHAK SAHAKARI PATPEDHI LTD, THANE

Accordingly, all the ground raised by the Revenue in appeal for the Assessment Year 2020-21 are dismissed

ITA 3434/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Aug 2024AY 2018-19

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri P.D. ChouguleFor Respondent: Shri Subodh Ratnaparikh
Section 143(3)Section 144BSection 80(2)(d)Section 80P(2)(d)Section 80P(4)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State for the registratio…

INCOME TAX OFFICER, ASHAR IT PARK,THANE vs. THANE JILLHA PRATHAMIK SIKSHAK SAHAKARI PATPEDHI LTD, WAGLE ESTATE,THANE

Accordingly, all the ground raised by the Revenue in appeal for the Assessment Year 2020-21 are dismissed

ITA 3433/MUM/2024[2020-21]Status: DisposedITAT Mumbai21 Aug 2024AY 2020-21

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri P.D. ChouguleFor Respondent: Shri Subodh Ratnaparikh
Section 143(3)Section 144BSection 80(2)(d)Section 80P(2)(d)Section 80P(4)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State for the registratio…

INCOME TAX OFFICER, PUNE vs. VISHWAKARMASARKSHANKAMGARSAHAKARI PATSANSTHA MARYADIT, PUNE

In the result, appeal of the Revenue in ITA

ITA 451/PUN/2024[2018-19]Status: DisposedITAT Pune09 Aug 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.450 & 451/Pun/2024 िनधा"रण वष" / Assessment Years:2017-18 &2018-19 The Income Tax Officer, V Vishwakarma Sarkshan Pune. S Kamgar Sahakari Patsanstha Maryadit, 185, Vishwakarma Bhuwan, Shaniwar Peth, Pune – 411030 Pan: Aaajv0492M Appellant/ Revenue Respondent /Assessee Cross Objection Nos.23 & 24/Pun/2024 (Arising Out Of Ita Nos.450 & 451/Pun/2024) िनधा"रणवष" / Assessment Years: 2017-18 & 2018-19 Vishwakarma Sarkshan V The Income Tax Kamgar Sahakari Patsanstha S Officer, Maryadit, 185, Vishwakarma Pune. Bhuwan, Shaniwar Peth, Pune – 411030 Pan: Aaajv0492M Appellant/ Revenue Respondent / Assessee Assessee By Shri S.N.Puranikh – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 07/08/2024 Date Of Pronouncement 09/08/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Revenue Has Filed Two Appeals For Two Separate Assessment Years I.E.2017-18 & 2018-19 Against Two Separate Orders Of

Section 250Section 80P(2)(a)Section 80P(2)(d)

…ds of a section particularly when the language of the section is clear and unambiguous but,being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section(vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered eitherunder the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State forthe registration…

INCOME TAX OFFICER, PUNE vs. VISHWAKARMA SARKSHAN KAMGAR SAHAKARI PATSANSTHA MARYADIT, PUNE

In the result, appeal of the Revenue in ITA

ITA 450/PUN/2024[2017-18]Status: DisposedITAT Pune09 Aug 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.450 & 451/Pun/2024 िनधा"रण वष" / Assessment Years:2017-18 &2018-19 The Income Tax Officer, V Vishwakarma Sarkshan Pune. S Kamgar Sahakari Patsanstha Maryadit, 185, Vishwakarma Bhuwan, Shaniwar Peth, Pune – 411030 Pan: Aaajv0492M Appellant/ Revenue Respondent /Assessee Cross Objection Nos.23 & 24/Pun/2024 (Arising Out Of Ita Nos.450 & 451/Pun/2024) िनधा"रणवष" / Assessment Years: 2017-18 & 2018-19 Vishwakarma Sarkshan V The Income Tax Kamgar Sahakari Patsanstha S Officer, Maryadit, 185, Vishwakarma Pune. Bhuwan, Shaniwar Peth, Pune – 411030 Pan: Aaajv0492M Appellant/ Revenue Respondent / Assessee Assessee By Shri S.N.Puranikh – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 07/08/2024 Date Of Pronouncement 09/08/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Revenue Has Filed Two Appeals For Two Separate Assessment Years I.E.2017-18 & 2018-19 Against Two Separate Orders Of

Section 250Section 80P(2)(a)Section 80P(2)(d)

…ds of a section particularly when the language of the section is clear and unambiguous but,being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section(vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered eitherunder the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State forthe registration…

DHANVARSHA NAGRI SAHAKARI PATASANTHA LIMITED,NAVI MUMBAI vs. ITO WARD 28(1)(3), NAVI MUMBAI

Accordingly, in view of paragraph 10 to 15 above, disallowance of INR.32,63,969/- is deleted and claim of deduction under Section 80P of the Act as made by the Appellant is allowed

ITA 1600/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Jul 2024AY 2014-15

Bench: the Tribunal. Therefore, the delay of 22 days in filing the appeal is condoned. 4. We note that the Appellant has raised the following grounds in the

For Appellant: Shri Vijaykumar ShindeFor Respondent: Shri R. R. Makwana
Section 143(3)Section 194HSection 40Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…of a section particularly when the language of the section is clear and unambiguous but, being part of the statute, it prima facie furnishes some clue as to the meaning and purpose of the section (vide Bengal Immunity Company Limited v. State of Bihar [1955] 2 SCR 603])." 28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State for the registratio…

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