What is Mantola Cooperative Thrift Credit Society Ltd. v. CIT authority for?

A cooperative society is not entitled to claim deduction under Section 80P of the Income Tax Act on interest income earned from deposits made with banks.

Which sections of the Income Tax Act does Mantola Cooperative Thrift Credit Society Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 80P(2)(a)(i), Section 80P(2)(d), Section 80P(4), Section 143(3), Section 1963, Section 143(2).

Mantola Cooperative Thrift Credit Society Ltd. v. CIT (110 DTR 89)

Q: How many judgments cite Mantola Cooperative Thrift Credit Society Ltd. v. CIT?

125 judgments on BharatTax cite Mantola Cooperative Thrift Credit Society Ltd. v. CIT (110 DTR 89), spanning 2018 to 2026.

Shri P Z Bagal Gramin Sah Patpedhi Ltd, Dhule vs. Income-Tax Officer, Ward 3, Dhule

In the result, both the appeals are allowed

ITA 329/PUN/2022[2017-18]Status: DisposedITAT Pune05 Aug 2022AY 2017-18

Bench: Shri R.S. Syalआयकर अपील सं. / Ita Nos.328 & 329/Pun/2022 "नधा"रण वष" / Assessment Years : 2015-16 & 2017-18

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

…ka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon’ble High Courts took into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. (supra). No direct judgment from the Hon’ble jurisdictional High Court on the point having been pointed out, the Tribunal in Shri Laxmi Naray…

Shri P Z Bagal Gramin Sah Patpedhi Ltd, Dhule vs. Income-Tax Officer, Ward 3, Dhule

In the result, both the appeals are allowed

ITA 328/PUN/2022[2015-16]Status: DisposedITAT Pune05 Aug 2022AY 2015-16

Bench: Shri R.S. Syalआयकर अपील सं. / Ita Nos.328 & 329/Pun/2022 "नधा"रण वष" / Assessment Years : 2015-16 & 2017-18

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

…ka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon’ble High Courts took into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. (supra). No direct judgment from the Hon’ble jurisdictional High Court on the point having been pointed out, the Tribunal in Shri Laxmi Naray…

Shri Shridharswamy Credit Souharda Sahakari Niyamit, Belagavi vs. ITO, Ward - 2(1), Belgavi

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

ITA 136/PAN/2018[2012-13]Status: DisposedITAT Panaji15 Jun 2022AY 2012-13

Bench: Shri C.M. Garg & Shri Girish Agrawal

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

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from Mahishwadagi Grama Seva Sahakari Sangh Ltd. vs. ITO banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High…

Income-Tax Officer Ward- 10(1), Akurdi vs. Shri Sainath Nagari Sahkari Patsanstha Maryadit, Ambegaon

In the result, the grounds raised by the Revenue in ITA No

ITA 75/PUN/2021[2017-18]Status: DisposedITAT Pune15 Jun 2022AY 2017-18

For Appellant: Shri M.G. JasnaniFor Respondent: None

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

…arnataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 taxmann 309 (Kar.) allowing the deduction u/s. 80P on interest income and the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income, earned from banks under similar circumstances. Both the Hon’ble High Courts have taken into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. 322 ITR 283 (SC). There being no direct judgment from the Hon’ble jurisdictional High Court on the point, the…

Income-Tax Officer, Ward-10(1), Akurdi vs. Vasantrao Naik Nagari Sahkari Patsanstha Maryadit, Alephata

In the result, the grounds raised by the Revenue in ITA No

ITA 74/PUN/2021[2017-18]Status: DisposedITAT Pune15 Jun 2022AY 2017-18

For Appellant: Shri M.G. JasnaniFor Respondent: None

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

…arnataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 taxmann 309 (Kar.) allowing the deduction u/s. 80P on interest income and the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income, earned from banks under similar circumstances. Both the Hon’ble High Courts have taken into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. 322 ITR 283 (SC). There being no direct judgment from the Hon’ble jurisdictional High Court on the point, the…

Prathamik Krishi Pattin Sahakari Sangh Niyamit Sankeshwar, Belgaum vs. ITO, Ward - 1(3), Belgaum

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 64/PAN/2018[2012-13]Status: DisposedITAT Panaji06 Apr 2022AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.64/Pan/2018 िनधा"रण वष" / Assessment Year : 2012-13 Prathamik Krishi Pattin Sahakhari Sangh Niyamit Sankeshwar, Azad Road, Sankeshwar, Tq: Hukkeri, Dist. Belgaum- 591313. .......अपीलाथ" / Appellant Pan : Aaaat4153E बनाम / V/S. Ito, Ward- 1(3), ……""यथ" / Respondent Belgaum. Assessee By : Shri M. S. Tigadi Revenue By : Shri Rijula Uniyal सुनवाई क" तारीख / Date Of Hearing : 04.04.2021 घोषणा क" तारीख / Date Of Pronouncement : 06.04.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Belagavi [‘Cit(A)’ For Short] Dated 29.11.2017 For The Assessment Year 2012-13. 2. Briefly, The Facts Of The Case Are That The Appellant Is A Cooperative Society Engaged In The Business Of Providing Credit Facilities To Its Members. The Return Of Income For The Assessment Year 2012-13 Was Filed On 15.09.2013 Declaring Rs.Nil Income. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax Officer, Ward- 1(3), Belgaum (‘The Assessing

For Appellant: Shri M. S. TigadiFor Respondent: Shri Rijula Uniyal

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

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High Court on the point, the Tribunal in Shri Laxmi Naray…

Sahyadri Sahakari Sakhar Karkhana Ltd, Kolhapur vs. Assistant Commissioner of Income-Tax, Circle - 2, Kolhapur

In the result, the appeal filed by the assessee in ITA

ITA 2255/PUN/2017[2013-14]Status: DisposedITAT Pune29 Mar 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarmaआयकर अपील सं. / Ita Nos.2254, 2255 & 2277/Pun/2017 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2014-15 Sahyadri Sahakari Sakhar Vs. Ito, Ward- 1(4), Karkhana Ltd., Kolhapur / C/O S.V. Phadnis C.A., Acit, Circle-2, 613, E Ward, Phadnis Kolhapur. Chambers, Shahupuri, 1St Lane, Kolhapur. Pan : Aaaas9803L Appellant Respondent Assessee By : None Revenue By Shri M. Jasnani : Date Of Hearing : 25.03.2022 Date Of Pronouncement : 29.03.2022 आदेश / Order Per Inturi Rama Rao, Am : These Are The Appeals Filed By The Assessee Directed Against The Different Orders Of Ld. Commissioner Of Income Tax (Appeals)-1, Kolhapur [(‘Cit(A)’ For Short] Commonly Dated 09.08.2017 For The Assessment Years 2012-13, 2013-14 & 2014-15 Respectively. 2. Since The Identical Facts & Issues Are Involved In All Above Three Appeals, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal In Ita No.2254/Pun/2017 For The Assessment Year 2012-13 Are Stated Herein.

For Appellant: None

Section 234ASection 80PSection 80P(2)(d)

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High Court on the point, the Tribunal in Shri Laxmi Naray…

Sahyadri Sahakari Sakhar Karkhana Ltd, Kolhapur vs. Income-Tax Officer, Ward - 1(4), Kolhapur

In the result, the appeal filed by the assessee in ITA

ITA 2254/PUN/2017[2012-13]Status: DisposedITAT Pune29 Mar 2022AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarmaआयकर अपील सं. / Ita Nos.2254, 2255 & 2277/Pun/2017 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2014-15 Sahyadri Sahakari Sakhar Vs. Ito, Ward- 1(4), Karkhana Ltd., Kolhapur / C/O S.V. Phadnis C.A., Acit, Circle-2, 613, E Ward, Phadnis Kolhapur. Chambers, Shahupuri, 1St Lane, Kolhapur. Pan : Aaaas9803L Appellant Respondent Assessee By : None Revenue By Shri M. Jasnani : Date Of Hearing : 25.03.2022 Date Of Pronouncement : 29.03.2022 आदेश / Order Per Inturi Rama Rao, Am : These Are The Appeals Filed By The Assessee Directed Against The Different Orders Of Ld. Commissioner Of Income Tax (Appeals)-1, Kolhapur [(‘Cit(A)’ For Short] Commonly Dated 09.08.2017 For The Assessment Years 2012-13, 2013-14 & 2014-15 Respectively. 2. Since The Identical Facts & Issues Are Involved In All Above Three Appeals, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal In Ita No.2254/Pun/2017 For The Assessment Year 2012-13 Are Stated Herein.

For Appellant: None

Section 234ASection 80PSection 80P(2)(d)

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High Court on the point, the Tribunal in Shri Laxmi Naray…

Sahyadri Sahakari Sakhar Karkhana Ltd, Kolhapur vs. Assistant Commissioner of Income-Tax, Circle - 2, Kolhapur

In the result, the appeal filed by the assessee in ITA

ITA 2277/PUN/2017[2014-15]Status: DisposedITAT Pune29 Mar 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarmaआयकर अपील सं. / Ita Nos.2254, 2255 & 2277/Pun/2017 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2014-15 Sahyadri Sahakari Sakhar Vs. Ito, Ward- 1(4), Karkhana Ltd., Kolhapur / C/O S.V. Phadnis C.A., Acit, Circle-2, 613, E Ward, Phadnis Kolhapur. Chambers, Shahupuri, 1St Lane, Kolhapur. Pan : Aaaas9803L Appellant Respondent Assessee By : None Revenue By Shri M. Jasnani : Date Of Hearing : 25.03.2022 Date Of Pronouncement : 29.03.2022 आदेश / Order Per Inturi Rama Rao, Am : These Are The Appeals Filed By The Assessee Directed Against The Different Orders Of Ld. Commissioner Of Income Tax (Appeals)-1, Kolhapur [(‘Cit(A)’ For Short] Commonly Dated 09.08.2017 For The Assessment Years 2012-13, 2013-14 & 2014-15 Respectively. 2. Since The Identical Facts & Issues Are Involved In All Above Three Appeals, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal In Ita No.2254/Pun/2017 For The Assessment Year 2012-13 Are Stated Herein.

For Appellant: None

Section 234ASection 80PSection 80P(2)(d)

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High Court on the point, the Tribunal in Shri Laxmi Naray…

Nivrutisheth Gramin Bigarsheti Sahakari Pat.Ltd, Pune vs. Income-Tax Officer, Ward - 10(5), Pune

In the result, the appeal is allowed

ITA 1502/PUN/2018[2015-16]Status: DisposedITAT Pune15 Mar 2022AY 2015-16

Bench: Shri R.S. Syalआयकर अपील सं. / Ita No.1502/Pun/2018 "नधा"रण वष" / Assessment Year : 2015-16

Section 2(19)Section 80PSection 80P(2)(a)

…taka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 taxmann 309 (Kar.) allowing the deduction u/s. 80P on interest income and the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income, earned from banks under similar circumstances. Both the Hon’ble High Courts have taken into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. 322 ITR 283 (SC). There being no direct judgment from the Hon’ble jurisdictional High Court on the point, th…

Sangli Zilla Dekharekh Sahakari Society Limited, Sangli vs. Income Tax Officer Ward-3, Sangli

In the result, the appeal is allowed

ITA 563/PUN/2020[2017-18]Status: DisposedITAT Pune01 Feb 2022AY 2017-18

Bench: Shri R.S. Syal

Section 80PSection 80P(2)Section 80P(2)(a)

…ka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon’ble High Courts took into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. (supra). No direct judgment from the Hon’ble 3 Sangli Zilla Dekharekh Sahakari Society Ltd., jurisdictional High Court on the point having be…

Deputy Commissioner of Income-Tax, Central Circla -2 (3), Pune vs. Shree Parshwanath Nagari Sah. Pat Sanstha Ltd, Satara

In the result, the appeal is dismissed

ITA 265/PUN/2019[2011-12]Status: DisposedITAT Pune27 Jan 2022AY 2011-12

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury"नधा"रण वष" / Assessment Year : 2011-12

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

…aka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon’ble High Courts took into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. (supra). No direct judgment from 3 the Hon’ble jurisdictional High Court on the point having been pointed out, the Tribunal in Shri Laxmi Nara…

Gurumauli Nagari Sahkari Pat Sanstha Marya Sangola, Pune, Sangola vs. Pr Commissioner of Income-Tax -4, Pune

In the result, the appeal is allowed

ITA 134/PUN/2021[2015-16]Status: HeardITAT Pune13 Jan 2022AY 2015-16

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi"नधा"रण वष" / Assessment Year : 2015-16

Section 143(3)Section 263Section 80PSection 80P(2)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE – VIRTUAL COURT BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER "नधा"रण वष" / Assessment Year : 2015-16 Gurumauli Nagari Sahkari Vs. Pr.CIT-4, Pat Sanstha Marya Sangola, Pune Mayakka Mauali Comersial Complex, Near ST stand, Sangole – 413 307 PAN : AAAAG4418M Appellant Respondent Assessee by Shri Shriram Puranik Revenue by Shri Mohit Jain Date of hearing 13-01-2022 Date of pronouncement 13-01-2022 आदेश / ORDER PER R.S.SYAL, VP : This appeal by the assessee is directed against the order passed by the Pr.CIT u/s.263…

Belgaum Coal & Coke Consumer Co-Op Association Ltd, Belgaum vs. ITO, Ward - 1(1), Belgavi

In the result, the appeal filed by the assessee stands allowed

ITA 103/PAN/2018[2012-13]Status: DisposedITAT Panaji17 Nov 2021AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.103/Pan/2018 िनधा"रण वष" / Assessment Year : 2012-13 Belgaum Coal & Coke Consumer Cooperative Association Ltd., Khanapur Road, Udyambag, Belgaum-590008. .......अपीलाथ" / Appellant Pan : Aaaat4615M बनाम / V/S. Ito, Ward- 1(1), ……""यथ" / Respondent Belagavi. Assessee By : Shri Shivanand Halbhari Revenue By : Shri Sourabh Nayak सुनवाई क" तारीख / Date Of Hearing : 12.11.2021 घोषणा क" तारीख / Date Of Pronouncement : 17.11.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Belagavi (‘Cit(A)’ For Short) Dated 23.01.2018 For The Assessment Year 2012-13. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. The Learned A.O. Has Erred In Not Allowing Deduction U/S 80P(2)(D) Of The Income Tax Act, 1961 Without Properly Verifying The Details Of Investee. 2. The Learned A.O. Has Wrongly Interpreted The Provisions Of Section 80P(2)(D) By Not Treating Investees I.E. Belgaum Industrial Cooperative Bank & Belgaum District Central Cooperative Bank As Cooperative Societies. 3. The Learned A.O. Has Wrongly Interpreted The Definition Of Cooperative Society Vide Section 2(19) Of The Income Tax Act, 1961 By Treating Those Entities Which Are Registered Under The Co-Operative Societies Act, 1912 (2 Of 1912), Or Under Any Other Law For The Time Being In Force In Any State For The Registration Of Co-Operative Societies, As Not Being Cooperative Societies.

For Appellant: Shri Shivanand HalbhariFor Respondent: Shri Sourabh Nayak

Section 143(3)Section 2(19)Section 80P(2)(a)Section 80P(2)(d)

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High Court on the point, the Tribunal in Shri Laxmi Naray…

The Hukkeri Taluka Agri Produce Co-Operative Marketing Society Limited, Sankeshwar vs. Income Tax Officer, Ward - 1(1), Belgavi

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 30/PAN/2018[2012-13]Status: DisposedITAT Panaji16 Nov 2021AY 2012-13

For Appellant: NoneFor Respondent: Shri Sourabh Nayak

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

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High Court on the point, the Tribunal in Shri Laxmi Naray…

Grama Seva Sahakari Sangh Ltd, Belgaum vs. Income Tax Officer, Ward - 1(4), Belagavi

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 1/PAN/2018[2013-14]Status: DisposedITAT Panaji15 Nov 2021AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.01/Pan/2018 िनधा"रण वष" / Assessment Year : 2013-14 Grama Seva Sahakari Sangh Ltd., Sankonhatti, Tq: Athani, Dist. Belgaum. .......अपीलाथ" / Appellant Pan : Aaaag0157B बनाम / V/S. Ito, Ward-1(4), ……""यथ" / Respondent Belagavi. Assessee By : Shri Shivanand Halbhavi Revenue By : Shri Sourabh Nayak सुनवाई क" तारीख / Date Of Hearing : 09.11.2021 घोषणा क" तारीख / Date Of Pronouncement : 15.11.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Gulbarga (‘Cit(A)’ For Short) Dated 26.10.2017 For The Assessment Year 2013-14. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. The Learned A.O. & Learned Cit (A) Have Erred In Disallowing Deduction Claimed Under Section 80P(2)(A) By Treating Is As Income From Other Sources. 2. The Learned A.O. Has Erred In Treating Income From Business & Profession As Income From Other Sources. 3. The Learned Ao & Learned Cit(A) Have Wrongly Interpreted The Provisions Of Sec 80P(2)(D) By Not Treating As Co-Op. Societies. 4. The Learned Ao Has Wrongly Interpreted The Definition Of Co-Op Society Vide Sec. 2(19) Of The It Act, 1961 By Treating Those Entities Which Are Registered Under The Co-Op Societies, 1912(2 Of 1912), Or Under Any Other Law For The Time Being In Force In Any State For The Registration Of Co-Op Societies, As Not Being Co-Op Societies.

For Appellant: Shri Shivanand HalbhaviFor Respondent: Shri Sourabh Nayak

Section 143(3)Section 2(19)Section 271(1)(c)Section 80(2)(d)Section 80P(2)(a)Section 80P(2)(d)

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High Court on the point, the Tribunal in Shri Laxmi Naray…

Mahishwadagi Grama Seva Sahakari Sangh Ltd, Mahishwadagi vs. ITO, Ward - 1(4), Belgaum

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 65/PAN/2018[2013-14]Status: DisposedITAT Panaji12 Nov 2021AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.65/Pan/2018 िनधा"रण वष" / Assessment Year : 2013-14 Mahishwadagi Grama Seva Sahakari Sangh Ltd., Mahishwadagi, Tal. Athani, Dist. Belagavi- 591304. .......अपीलाथ" / Appellant Pan : Aaaam0355P बनाम / V/S. Ito, Ward-1(4), ……""यथ" / Respondent Belgaum. Assessee By : Shri Chetan Chougule Revenue By : Shri Sourabh Nayak सुनवाई क" तारीख / Date Of Hearing : 08.11.2021 घोषणा क" तारीख / Date Of Pronouncement : 12.11.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Gulbarga (‘Cit(A)’ For Short) Dated 30.11.2017 For The Assessment Year 2013-14. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. Because The Commissioner Of Income Tax (Appeals) Has Overlooked The Facts Of The Case & Not Taken Into Account The Submissions Given By The Appellant With Respect To Interest Received From Mandatory Statutory Deposits Kept With District Central Bank & Also Dividend Received From Such Mandatory Investments & Considered Them As Income From Other Sources & Also Interest Received From Savings Bank A/C Is Also Considered As Income From Other Sources, Instead Of Considering The Same As Income Attributable To Providing Credit Facilities To Its Members & Denied The Deduction Claimed Under Section 80P(2)(A)(I) Of Income Tax Act, 1961. 2. Because, The Learned Assessing Officer Erred In Denying The Deduction Claimed Under Section 80P(2)(A)(I) Of Income Tax Act, 1961. 3. Because The Learned Assessing Officer Has Overlooked The Facts Of The Case With Respect To Interest Received From Mandatory Statutory Deposits Kept With District Central Bank & Also Dividend Received From Such Mandatory

For Appellant: Shri Chetan ChouguleFor Respondent: Shri Sourabh Nayak

Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

…ataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (2010) 322 ITR 283 (SC). There being no direct judgment from the Hon'ble jurisdictional High Court on the point, the Tribunal in Shri Laxmi Naray…

Sant Motiram Maharaj Sahakari Pat. Sanstha Ltd, Parbhani vs. Income-Tax Officer, Ward - Parbhani, Parbhani

In the result, the appeal is allowed

ITA 826/PUN/2019[2014-15]Status: DisposedITAT Pune23 Sept 2020AY 2014-15

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviिनधा"रण वष" / Assessment Year : 2014-15 Sant Motiram Maharaj Sahakari Vs. Ito, Pat Sanstha Ltd., Ward Chate Building, New Mondha, Parbhani Near Sbh, Gangakhed, Dist. Parbhani, Maharashtra – 431 514 Pan : Aadas3137Q Appellant Respondent Assessee By Smt. Deepa Khare Revenue By Shri Deepak Garg Date Of Hearing 16-09-2020 Date Of Pronouncement 23-09-2020 आदेश / Order Per R.S.Syal, Vp : This Appeal By The Assessee Emanates From The Order Dated 28-03-2019 Passed By The Pr. Commissioner Of Income-Tax-1, Aurangabad U/S.263 Of The Income-Tax Act, 1961 (Hereinafter Also Called ‘The Act’) In Relation To The Assessment Year 2014-15. 2. Succinctly, The Facts Of The Case Are That The Assessee Is A Credit Co-Operative Society Providing Credit Facility To Its Members. A Return Was Filed Declaring Nil Income. Assessment U/S 143(3) Of 2 Sant Motiram Maharaj Sah. Pat Sanstha Ltd.

Section 143(3)Section 244ASection 263Section 80PSection 80P(1)Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE – VIRTUAL COURT BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER िनधा"रण वष" / Assessment Year : 2014-15 Sant Motiram Maharaj Sahakari Vs. ITO, Pat Sanstha Ltd., Ward Chate Building, New Mondha, Parbhani Near SBH, Gangakhed, Dist. Parbhani, Maharashtra – 431 514 PAN : AADAS3137Q Appellant Respondent Assessee by Smt. Deepa Khare Revenue by Shri Deepak Garg Date of hearing 16-09-2020 Date of pronouncement 23-09-2020 आदेश / ORDER PER R.S.SYAL, VP : This appeal by the assessee emanates from the order dated 28-03-2019 passed…

Sureshdada Jain Nagari Sahakari Patsanstha Maryadit, Jalgaon vs. Principal Commissioner of Income-Tax : 2

In the result, the appeal is allowed on merits

ITA 713/PUN/2016[2011-12]Status: DisposedITAT Pune09 Apr 2019AY 2011-12

Bench: Shri R.S. Syal & Shri Vikas Awasthy

Section 143(3)Section 263Section 80PSection 80P(2)(c)

…gh Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 taxmann 309 (Kar.) allowing the deduction u/s. 80P on interest income and that of the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income, earned from banks under similar circumstances. Both the Hon’ble High Courts have taken into consideration the ratio 4 Sureshdada Jain Nagari Sahakari Patsanstha Maryadit laid down in the case of Totgar’s Cooperative Sale Society Ltd. 322 ITR 283 (SC). There being no direct judgment fr…

Sumitra Gramin Bigar Sheti Sahakari Pat Sanstha Maryadit, Solapur vs. Income-Tax Officer

Appeal of the assessee is partly allowed

ITA 2476/PUN/2016[2008-09]Status: DisposedITAT Pune25 Jan 2019AY 2008-09

Bench: Shri R.S.Syal & Shri Partha Sarathi Chaudhury, Jm

For Appellant: Shri Sunil GanooFor Respondent: Shri S. Das

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

…arnataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 taxmann 309 (Kar.) allowing the deduction u/s. 80P on interest income and the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income, earned from banks under similar circumstances. Both the Hon’ble High Courts have taken into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. 322 ITR 283 (SC). There being no direct judgment from the Hon’ble jurisdictional High Court on the point, the…

Mantola Cooperative Thrift Credit Society Ltd. v. CIT

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Judgments citing Mantola Cooperative Thrift Credit Society Ltd. v. CIT

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Shri P Z Bagal Gramin Sah Patpedhi Ltd, Dhule vs. Income-Tax Officer, Ward 3, Dhule

Shri Shridharswamy Credit Souharda Sahakari Niyamit, Belagavi vs. ITO, Ward - 2(1), Belgavi

Income-Tax Officer Ward- 10(1), Akurdi vs. Shri Sainath Nagari Sahkari Patsanstha Maryadit, Ambegaon

Income-Tax Officer, Ward-10(1), Akurdi vs. Vasantrao Naik Nagari Sahkari Patsanstha Maryadit, Alephata

Prathamik Krishi Pattin Sahakari Sangh Niyamit Sankeshwar, Belgaum vs. ITO, Ward - 1(3), Belgaum

Sahyadri Sahakari Sakhar Karkhana Ltd, Kolhapur vs. Assistant Commissioner of Income-Tax, Circle - 2, Kolhapur

Sahyadri Sahakari Sakhar Karkhana Ltd, Kolhapur vs. Income-Tax Officer, Ward - 1(4), Kolhapur

Sahyadri Sahakari Sakhar Karkhana Ltd, Kolhapur vs. Assistant Commissioner of Income-Tax, Circle - 2, Kolhapur

Nivrutisheth Gramin Bigarsheti Sahakari Pat.Ltd, Pune vs. Income-Tax Officer, Ward - 10(5), Pune

Sangli Zilla Dekharekh Sahakari Society Limited, Sangli vs. Income Tax Officer Ward-3, Sangli

Deputy Commissioner of Income-Tax, Central Circla -2 (3), Pune vs. Shree Parshwanath Nagari Sah. Pat Sanstha Ltd, Satara

Gurumauli Nagari Sahkari Pat Sanstha Marya Sangola, Pune, Sangola vs. Pr Commissioner of Income-Tax -4, Pune

Belgaum Coal & Coke Consumer Co-Op Association Ltd, Belgaum vs. ITO, Ward - 1(1), Belgavi

The Hukkeri Taluka Agri Produce Co-Operative Marketing Society Limited, Sankeshwar vs. Income Tax Officer, Ward - 1(1), Belgavi

Grama Seva Sahakari Sangh Ltd, Belgaum vs. Income Tax Officer, Ward - 1(4), Belagavi

Mahishwadagi Grama Seva Sahakari Sangh Ltd, Mahishwadagi vs. ITO, Ward - 1(4), Belgaum

Sant Motiram Maharaj Sahakari Pat. Sanstha Ltd, Parbhani vs. Income-Tax Officer, Ward - Parbhani, Parbhani

Sureshdada Jain Nagari Sahakari Patsanstha Maryadit, Jalgaon vs. Principal Commissioner of Income-Tax : 2

Sumitra Gramin Bigar Sheti Sahakari Pat Sanstha Maryadit, Solapur vs. Income-Tax Officer