Citizen Co-operative Society Limited v. Commissioner of Income Tax

9 SCC 364Reported decision2017#3777 most cited

What is Citizen Co-operative Society Limited v. Commissioner of Income Tax authority for?

The Supreme Court decision in Citizen Co-operative Society Ltd. (2017) 9 SCC 364 is distinguished in later judgments, particularly Mavilayi Service Co-operative Bank Ltd. vs. Commissioner of Income Tax, on the basis that the earlier case did not consider arguments regarding the assessing officer's ability to examine the cooperative society's business operations beyond its registration.

32

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

Citizen Co-operative Society Ltd. · 80P · section 80P(2)(a)(i) · Mavilayi Service Co-operative Bank Ltd. · cooperative society deduction · income tax · Supreme Court

Sections most often in play

Section 80P(2)(d)Section 80P(4)Section 80PSection 80P(2)(a)(i)Section 250Section 142(1)Section 143(1)Section 143(2)

Issues it is cited on

section 56(cci)section 5(b)section 22(1)(b)section 80jjsection 22(1)section 61section 80p(1)section 2(19)section 80p(4)section 80jsection 80hsection 80p(2)(a)

Judgments citing Citizen Co-operative Society Limited v. Commissioner of Income Tax

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)

…see based on the decision of the Hon'ble Supreme Court in case of Citizen Cooperative Society. 9. Honourable Supreme Court had an occasion later on to consider this decision of the Honourable Supreme Court in case of Citizen Cooperative Society Limited (2017) 9 SCC 364 in the another decision of the larger bench of the Honourable Supreme Court in Mavilayi Service Co-operative Bank Ltd. vs. Commissioner of Income Tax, Calicut [2021] 123 taxmann.com 161 (SC)/[2021] 279 Taxman 75 (SC)/[2021] 431 ITR 1 (SC)[12-01-2021] wherein it was held as under:- "20. We now come to the judgment of this Court in Citizen Cooperativ…

CHARKOP LANDS END COOPERATIVE HOUSING SOCIETY LTD,KANDIVALI WEST MUMBAI vs. ITO, KAUTILYA BHAVAN, BKC, MUMBAI

In the result, the assessee’s appeal is allowed

ITA 2843/MUM/2024[2020-2021]Status: DisposedITAT Mumbai15 Oct 2024AY 2020-2021

Bench: SHRI OM PRAKASH KANT (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(1)Section 2(19)Section 250Section 5Section 80PSection 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘H(SMC)’ BENCH MUMBAI BEFORE: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER Charkop Lands End Vs. ITO, Co-operative Kautilya Bhavan, BKC, Housing Society Ltd. Mumbai. Plot No. 23, Lands End Chs, Netaji Subhashchandra Bose Marg, Sector 2A, Charkop, Kandivali West, 400067. PAN/GIR No. AAAAC4607J (Appellant) .. (Respondent) Assessee by Shri. Siddharth Sunil Bhandari, ACA Revenue by Shri. Asif Karmali, Sr. DR Date of Hearing 30/07/2024 Date of Pronouncement 15/10/2024 आदेश / O R D E R PER SUNIL KUMAR SINGH (J.M): 1. This appeal has been p…

STELLA MARIS CO-OPERATIVE HOUSING SOCIETY LTD,MUMBAI vs. INCOME TAX OFFICER WARD 22(3)(6)(, MUMBAI

In the result, the assessee’s appeal is allowed

ITA 1762/MUM/2024[2015-16]Status: DisposedITAT Mumbai15 Oct 2024AY 2015-16

Bench: SHRI BR BASKARAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(1)Section 2(19)Section 250Section 5Section 80PSection 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘J(SMC)’ BENCH MUMBAI BEFORE: SHRI BR BASKARAN, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER Stella Maris Co- Vs. Income Tax Officer Ward operative Housing 22(3)(6) Society Ltd. Piramal Chambers Lal Sitaladevi Temple Baug, Parel-400012, Road, Mahim, 400016. Mumbai-400016. PAN/GIR No. AADAS1717Q (Appellant) .. (Respondent) Assessee by Shri. Ajay Arvind Wadke Revenue by Shri. Ajit Pal Singh Daia (Sr. AR) Date of Hearing 18/07/2024 Date of Pronouncement 15/10/2024 आदेश / O R D E R PER SUNIL KUMAR SINGH (J.M): 1. This appeal has been preferred against the im…

VADAKKEVILA SERVICE CO-OPERATIVE BANK LTD,KOLLAM vs. THE ITO, KOLLAM

Appeal is allowed in above terms

ITA 478/COCH/2023[2017-18]Status: DisposedITAT Cochin25 Sept 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Ms.Anoopa, AdvocateFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 194ASection 40Section 56Section 80PSection 80P(2)Section 80P(2)(a)

…s a fit instance to hold that the same indeed is eligible to claim sec.80P(2)(a)(i) deduction. The assessee’s fourth substantive ground is accepted accordingly. 7. Learned CIT-DR further submits in light of Citizen Co- operative Society Ltd., vs. ACIT (2017) 9 SCC 364 that the assessee has derived its interest income from non-member and therefore, the impugned disallowance deserves to be confirmed u/s.80P of the Act. We are of the considered view that their lordships’ foregoing decision stand distinguished in assessee’s favour in Mavilayi Service Co-operative Bank Ltd., v. CIT (2021) 431 ITR 1 (SC) and therefore…

M/S IJMIMA IMITATION JEWELLERY MARKET SOCIETY LIMITED ,MUMBAI vs. AO CIRCLE 41(3)(1), MUMBAI

ITA 1618/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Sept 2024AY 2018-19
Section 143(2)Section 2(19)Section 250Section 5Section 80PSection 80P(2)(d)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI BR BASKARAN, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ITA No. 1618/MUM/2024 (Assessment Year : 2018-19) M/s Ijmima Imitation Jewellery Vs. AO, Circle 41(3)(1) Kautilya Bhavan, Market Society Mumbai-400051. Limited Society Office Ijmima Complex, Raheja Metroplex, Link Road, Malad(W), Mumbai-400064. PAN/GIR No. AAAA16896F (Appellant) (Respondent) Assessee by Shri. Aajay Singh Revenue by Shri. H.M. Bhatt (Sr. DR) Date of Hearing 20/06/2024 Date of Pronouncement 19/09/2024 आदेश / ORDER PER SUNIL KUMAR SINGH (J.M): 1. This appeal…

THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOTTAYAM vs. M/S.SAHYADRI CO-OPERATIVE CREDIT SOCEITY LIMITED

The appeal is disposed of as indicated above

ITA/1/2018HC Kerala04 Sept 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Appellant: THE PRINCIPAL COMMISSIONER OF INCOME TAXFor Respondent: M/S. SAHYADRI CO-OPERATIVE CREDIT SOCIETY LTD

…a and Mahindra Ltd. [(1983) 4 SCC 392]). Therefore, it hardly needs to be emphasised that all those cooperative societies which fall within the purview of Section 80-P of the Act are entitled to deduction in respect of any income referred to 3 (2017) 9 SCC 364 ITA Nos.68/2017, 196/2019, 63/2019, 1/2018, 219/2019 -21- in sub-section (2) thereof. Clause (a) of sub-section (2) gives exemption of whole of the amount of profits and gains of business attributable to any one or more of such activities which are mentioned in sub-section (2). Therefore, the definition is in the Income Tax Act from…

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S.SAHYADRI CO-OPERATIVE CREDIT SOCIETY LTD.

The appeal is disposed of as indicated above

ITA/196/2019HC Kerala04 Sept 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Appellant: THE PRINCIPAL COMMISSIONER OF INCOME TAXFor Respondent: M/S. SAHYADRI CO-OPERATIVE CREDIT SOCIETY LTD

…a and Mahindra Ltd. [(1983) 4 SCC 392]). Therefore, it hardly needs to be emphasised that all those cooperative societies which fall within the purview of Section 80-P of the Act are entitled to deduction in respect of any income referred to 3 (2017) 9 SCC 364 ITA Nos.68/2017, 196/2019, 63/2019, 1/2018, 219/2019 -21- in sub-section (2) thereof. Clause (a) of sub-section (2) gives exemption of whole of the amount of profits and gains of business attributable to any one or more of such activities which are mentioned in sub-section (2). Therefore, the definition is in the Income Tax Act from…

BLUE ROSE INDUSTRIAL PREMISES CO-OP SOCIETY LTD ,MUMBAI vs. INCOME TAX OFFICER, WARD - 42(1)(1),, MUMBAI

In the result, the assessee’s appeal ITA NO

ITA 2330/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 Aug 2024AY 2018-19

Bench: SHRI PRASHANT MAHARISHI (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(2)Section 250Section 270ASection 80PSection 80P(2)(d)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K(SMC)’ BENCH MUMBAI BEFORE: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ITA No. 2329/MUM/2024 (Assessment Year : 2021–22) Blue Rose Industrial Vs. JAO- Income Tax Officer Premises Co-op Ward(1)(1) Society Ltd Kautilya Bhawan, 43, Blue Rose “G” Block Bandra Kurla Industrial Premises Complex, Co-op Society Ltd, Bandra (East), Western Express Mumbai-400051. Highway, Borivali(East), Mumbai-400068. PAN/GIR No. AAAAB3779Q (Appellant) .. (Respondent) Assessee by Shri. Ajay Singh Revenue by Shri. Rajneesh Yadav Sr. DR Date of Hearing 2…

BLUE ROSE INDUSTRIAL PREMISES CO-OP SOCIETY LTD ,MUMBAI vs. INCOME TAX OFFICER, WARD - 42(1)(1), MUMBAI, MUMBAI

In the result, the assessee’s appeal ITA NO

ITA 2329/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 Aug 2024AY 2021-22

Bench: SHRI PRASHANT MAHARISHI (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(2)Section 250Section 270ASection 80PSection 80P(2)(d)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K(SMC)’ BENCH MUMBAI BEFORE: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ITA No. 2329/MUM/2024 (Assessment Year : 2021–22) Blue Rose Industrial Vs. JAO- Income Tax Officer Premises Co-op Ward(1)(1) Society Ltd Kautilya Bhawan, 43, Blue Rose “G” Block Bandra Kurla Industrial Premises Complex, Co-op Society Ltd, Bandra (East), Western Express Mumbai-400051. Highway, Borivali(East), Mumbai-400068. PAN/GIR No. AAAAB3779Q (Appellant) .. (Respondent) Assessee by Shri. Ajay Singh Revenue by Shri. Rajneesh Yadav Sr. DR Date of Hearing 2…

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, appeal of the assessee is allowed

ITA 696/MUM/2024[2013-14]Status: DisposedITAT Mumbai29 Aug 2024AY 2013-14

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sunil Kumar Singh, Hon’Ble

For Appellant: Shri Bhupendra Shah, A/RFor Respondent: Shri R.R. Makwana, Sr. D/R
Section 22Section 5Section 56Section 80P

…| आयकर अपीलीय अिधकरण "ायपीठ, मुंबई | IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, HON’BLE ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, HON’BLE JUDICIAL MEMBER I.T.A. No. 696/Mum/2024 Assessment Year: 2013-14 CIDCO Employees’ Co-op. Credit Income Tax Officer, 28(1)(3), Society Ltd. Mumbai Vs Ground Floor, CIDCO Bhavan CBD-Belapur Navi Mumbai - 400614 [PAN: AAAAC2203N] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Bhupendra Shah, A/R Revenue by : Shri R.R. Makwana, Sr. D/R सुनवाई की तारीख/Date of Hearing : 27/08/2024 घोषणा की तारीख/Date of Pronouncem…

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 699/MUM/2024[2018-19]Status: DisposedITAT Mumbai07 Aug 2024AY 2018-19

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

…Reportable IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI GAGAN GOYAL, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ITA No. 698/MUM/2024 (Assessment Year : 2017–18) CIDCO Employees Vs. ITO Ward 28(1)(3) Co–op. Credit 3rd Floor, Tower no. 6, Society, Vashi Railway Station, Ground Floor, Vashi, Navi Mumbai, CIDCO Bhavan, 400703. CBD–Belapur, Navi Mumbai, 400614. PAN/GIR No. AAAAC2203N (Appellant) .. (Respondent) Assessee by Shri. Bhupendra Shah Revenue by Shri. H.M. Bhatt (SR. DR.) Date of Hearing 03/06/2024 (in ITA no. 698/Mum/2024 & ITA no. 699/MUM/2024) 04/06/2024 (in ITA…

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 698/MUM/2024[2017-18]Status: DisposedITAT Mumbai07 Aug 2024AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

…Reportable IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI GAGAN GOYAL, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ITA No. 698/MUM/2024 (Assessment Year : 2017–18) CIDCO Employees Vs. ITO Ward 28(1)(3) Co–op. Credit 3rd Floor, Tower no. 6, Society, Vashi Railway Station, Ground Floor, Vashi, Navi Mumbai, CIDCO Bhavan, 400703. CBD–Belapur, Navi Mumbai, 400614. PAN/GIR No. AAAAC2203N (Appellant) .. (Respondent) Assessee by Shri. Bhupendra Shah Revenue by Shri. H.M. Bhatt (SR. DR.) Date of Hearing 03/06/2024 (in ITA no. 698/Mum/2024 & ITA no. 699/MUM/2024) 04/06/2024 (in ITA…

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 697/MUM/2024[2014-15]Status: DisposedITAT Mumbai07 Aug 2024AY 2014-15

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

…Reportable IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI GAGAN GOYAL, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ITA No. 698/MUM/2024 (Assessment Year : 2017–18) CIDCO Employees Vs. ITO Ward 28(1)(3) Co–op. Credit 3rd Floor, Tower no. 6, Society, Vashi Railway Station, Ground Floor, Vashi, Navi Mumbai, CIDCO Bhavan, 400703. CBD–Belapur, Navi Mumbai, 400614. PAN/GIR No. AAAAC2203N (Appellant) .. (Respondent) Assessee by Shri. Bhupendra Shah Revenue by Shri. H.M. Bhatt (SR. DR.) Date of Hearing 03/06/2024 (in ITA no. 698/Mum/2024 & ITA no. 699/MUM/2024) 04/06/2024 (in ITA…

M/S. THE FARIDKOT PRIMARY COOP AGRICULTURAL DEVELOPMENT BANK.LIMITED,FARIDKOT vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3, FEROZEPUR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 288/ASR/2019[2015-16]Status: DisposedITAT Amritsar11 Aug 2022AY 2015-16

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. P. N. Arora, AdvFor Respondent: Sh. Manpreet Singh Duggal, Sr. DR
Section 143(3)Section 80Section 80PSection 80P(2)(c)Section 80P(4)

…-operative Bank Ltd. v. CIT, Calicut [2021] 123 taxmann.com 161 (SC) page nos. 18 to 44. 8. The ld. DR has supported the order of the CIT(A) and placed reliance on the Hon’ble Apex Court in the case of Citizen Cooperative Society Ltd. v. ACIT Hyderabad [2017] 9 SCC 364. 5 The Faridkot Primary Coop. A. D. B. Ltd. v. DCIT 9. We have heard both the sides and perused the material available on the record and case laws cited before us. The Ld. CIT (A) has mentioned that the appellant is a Cooperative Agricultural Development Bank Ltd. and not a Primary Agricultural Credit Society and also not an Agricultural and Rural…

KODAVOOR VYAVASAYA SEVA SAHAKARI SANGHA NIYAMITHA vs. ASSESSING OFFICER

Accordingly, petition is dismissed

WP/20091/2021HC Karnataka11 Feb 2022

Bench: The Hon'Ble Mr.Justice S. Sunil Dutt Yadav

Section 246

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 11TH DAY OF FEBRUARY, 2022 BEFORE THE HON'BLE MR.JUSTICE S. SUNIL DUTT YADAV WRIT PETITION No.20091/2021 (T-IT) BETWEEN: KODAVOOR VYAVASAYA SEVA SAHAKARI SANGHA NIYAMITHA 16-62, KODAVOOR, POST KODAVOOR, UDUPI - 576 106 REPRESENTED BY ITS C.E.O., MR. SUDHAKAR AGE:46 YEARS. … PETITIONER (BY SRI MAHESH R. UPPIN, ADVOCATE) AND: 1. ASSESSING OFFICER NATIONAL FACELESS ASSESSMENT CENTRE DELHI - 110 001. 2. INCOME TAX OFFICER WARD-1 & TPS AAYAKAR BHAVAN ADI-UDUPI MALPE…

JUMBO TECHNO SERVICES PVT LTD.,MUMBAI vs. ASST CIT 3 (3), MUMBAI

In the result, assessee’s appeal is allowed

ITA 6802/MUM/2019[2010-11]Status: DisposedITAT Mumbai03 Feb 2022AY 2010-11

Bench: Shri Shamim Yahya (Am) & Shri Rahul Chaudhary (Jm) I.T.A. No. 6802/Mum/2019 (Assessment Year 2010-11) Vs. Acit-3(3) Jumbo Techno Services Ltd. 171, C Wing, Mittal Court Aaykar Bhawan Nariman Point M.K.Road Mumbai-400 021 Mumbai-400 020 Pan : Aabcj8752C (Appellant) (Respondent) Shri Aakash Marthak Assessee By Department By Shri S.N.Kabra Date Of Hearing 01.02.2022 Date Of Pronouncement 03.02.2022

Section 271(1)(c)Section 274Section 80P(2)(a)Section 80P(4)

…a three-Judge Bench of the Supreme Court has decided Mavilayi. 165. Mavilayi has noted that the Full Bench of Kerala High Court has reached its conclusion based on the Supreme Court's judgment Citizen Cooperative Society Ltd. v, Asst. CIT, Hyderabad [(2017) 9 SCC 364]. Indeed, Mavilayi acknowledges that the Kerala High Court's Full Bench did follow Citizen Cooperative. But it holds that in Citizen Cooperative Society Ltd., the counsel for the assessee advanced no argument that "the assessing officer and other authorities under the IT Act could not go behind the registration of the I co-operative society in orde…

SHORLINE HOTEL P. LTD.,MUMBAI vs. DY CIT- CC-1(2), MUMBAI

In the result, all these appeals by the assessee stand partly allowed

ITA 253/MUM/2021[2009-10]Status: DisposedITAT Mumbai18 Jan 2022AY 2009-10

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

Section 271(1)(c)Section 80P(2)(a)Section 80P(4)

…a three-Judge Bench of the Supreme Court has decided Mavilayi. 165. Mavilayi has noted that the Full Bench of Kerala High Court has reached its conclusion based on the Supreme Court's judgment Citizen Cooperative Society Ltd. v, Asst. CIT, Hyderabad [(2017) 9 SCC 364]. Indeed, Mavilayi acknowledges that the Kerala High Court's Full Bench did follow Citizen Cooperative. But it holds that in Citizen Cooperative Society Ltd., the counsel for the assessee advanced no argument that "the assessing officer and other authorities under the IT Act could not go behind the registration of the I co-operative society in orde…

M/S APACE REALTY ,THANE vs. ITO WARD 2(1) , KALYAN

In the result, both the assessee’s appeals are allowed

ITA 607/MUM/2020[2015-16]Status: DisposedITAT Mumbai14 Dec 2021AY 2015-16

Bench: Shri Shamim Yahya

Section 271GSection 92Section 92BSection 92DSection 92D(3)

…a three-Judge Bench of the Supreme Court has decided Mavilayi. 165. Mavilayi has noted that the Full Bench of Kerala High Court has reached its conclusion based on the Supreme Court's judgment Citizen Cooperative Society Ltd. v, Asst. CIT, Hyderabad [(2017) 9 SCC 364]. Indeed, Mavilayi acknowledges that the Kerala High Court's Full Bench did follow Citizen Cooperative. But it holds that in Citizen Cooperative Society Ltd., the counsel for the assessee advanced no argument that "the assessing officer and other authorities under the IT Act could not go behind the registration of the I co-operative society in orde…

SHRI RAJENDRA P. JAIN ,MUMBAI vs. DYCIT, CENTRAL CIR.-1(3), MUMBAI

In the result, assessee’s appeals are allowed

ITA 190/MUM/2021[2013-14]Status: DisposedITAT Mumbai08 Dec 2021AY 2013-14

Bench: Shri Shamim Yahya (Am) & Shri Laliet Kumar (Jm) I.T.A. Nos. 190 To 192/Mum/2021 (Assessment Years : 2012-13,2013-14 & 2014-15) Rajendra P.Jain Dcit,Cc-1(3) Vs. A-1605, Samarpan 905, 9Th Floor Exotica, Off.Dattapada Old Cgo Building Road, Behind Metro Mall, Prathishta Bhawan Borivali(E) M.K.Road, Mumbai-400 066 Mumbai-400 020 Pan : Abhpj0579P (Appellant) (Respondent)

Section 132(1)Section 143(3)Section 153Section 153ASection 271Section 271(1)Section 271(1)(C)Section 271(1)(c)

…, a three-Judge Bench of the Supreme Court has decided Mavilayi. 165. Mavilayi has noted that the Full Bench of Kerala High Court has reached its conclusion based on the Supreme Court's judgment Citizen Cooperative Society Ltd. v, Asst. CIT, Hyderabad [(2017) 9 SCC 364]. Indeed, Mavilayi acknowledges that the Kerala High Court's Full Bench did follow Citizen Cooperative. But it holds that in Citizen Cooperative Society Ltd., the counsel for the assessee advanced no argument that "the assessing officer and other authorities under the IT Act could not go behind the registration of the I co-operative society in orde…

SHRI GUFRAN AHMED CHAUDHARI,,VALSAD vs. THE INCOME TAX OFFICER, VAPI WARD-1,, VAPI

In the result, appeals of the Assessees (in ITA No

ITA 623/SRT/2018[2011-12]Status: DisposedITAT Surat26 Nov 2021AY 2011-12

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.618/Srt/2018 (िनधा"रणवष" / Assessment Year: (2011-12) (Virtual Court Hearing) Prakash F Singh, The Income Tax Officer, V Ward-7, Room No.810, 8Th Floor, Rbl, 63/751, Chanod Colony, Gidc, S. Vapi-396195 Fortune Square-Ii, Vapi Daman Road, Chala, Vapi-396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Asnps 4835N (Assessee) (Respondent)

For Appellant: Shri A. Gopalakrishnan,C.AFor Respondent: Mrs. AnupamaSingla– Sr.DR
Section 143(2)Section 143(3)Section 271Section 271(1)(c)

…, a three-Judge Bench of the Supreme Court has decided Mavilayi. 165. Mavilayi has noted that the Full Bench of Kerala High Court has reached its conclusion based on the Supreme Court's judgment Citizen Cooperative Society Ltd. v. Asst. CIT, Hyderabad [(2017) 9 SCC 364]. Indeed, Mavilayi acknowledges that the Kerala High Court's Full Bench did follow Citizen Cooperative. Case (supra) But it holds that in Citizen Cooperative Society Ltd. Case (supra) the counsel for the assessee advanced no argument that "the assessing officer and other authorities under the IT Act could not go behind the registration of the co-op…

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