The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara
In the result, the appeal of the assessee is allowed for statistical
ITA 2156/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21
Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara Pan: Aaaat1502B अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.
For Appellant: Department byFor Respondent: Date of hearing
Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)
…come by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society. To become eligible for deduction, the investment has to be made in another Co-operative Society. The Hon'ble SC in Totgar's case 322 ITR 383 has held that the assessee would not be eligible for deduction under Section 80P(2)(d) in relation to interest income earned from Co-operative banks. It is common for the appellants in the cases involving this issue to rely on the Hon'ble Kamataka HC decision in the case of Totgar's Co-operative sale society 392 ITR 74 and argue that it is held i…