How many judgments cite Mavilayi Service Co-operative Bank Ltd. v. CIT?

999 judgments on BharatTax cite Mavilayi Service Co-operative Bank Ltd. v. CIT (431 ITR 1), spanning 2017 to 2026.

Which sections of the Income Tax Act does Mavilayi Service Co-operative Bank Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 80P(2)(d), Section 80P(4), Section 80P(2)(a)(i), Section 80P, Section 143(3), Section 250.

Mavilayi Service Co-operative Bank Ltd. v. CIT

431 ITR 1Supreme Court of India2021#42 most cited

What is Mavilayi Service Co-operative Bank Ltd. v. CIT authority for?

Section 80P(4) serves as a proviso to Section 80P(1) and (2), excluding only cooperative banks that are cooperative societies and possess an RBI license for banking business. Its purpose is to exclude cooperative banks operating like commercial banks that lend money to the public.

999

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2017 to 2026.

Also referred to as

Mavilayi Service Co-operative Bank Ltd. v. CIT · Section 80P(4) · Section 80P(1) · Section 80P(2) · cooperative bank deduction · RBI license · banking business · cooperative society · deduction under Section 80P(2)(d) · exclusion from 80P · 431 ITR 1

Also reported as

123 Taxmann.com 161279 Taxmann 75

Sections most often in play

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

Issues it is cited on

section 22(1)(b)section 5(b)section 80p(1)section 80p(4)section 2(19)section 80p(2)(c)section 22(1)section 80p(2)(a)section 80p(2)(a)(i)section 70 section 80p(2)section 80p(2)(d)

Judgments citing Mavilayi Service Co-operative Bank Ltd. v. CIT

Income Tax Officer Ward-2, Khamgaon vs. Maharashtra Urban Co-Operative Credit Society Ltd, Mehkar

In the result, appeals for A

ITA 635/NAG/2024[2018]Status: DisposedITAT Nagpur25 Feb 2025

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke

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

…IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY, ACCOUNTANT, MEMBER ITA no.635, 636 and 637/Nag./2024 (Assessment Year : 2018–19, 20-21 and 2022-23) Income Tax Officer ……………. Appellant Ward–2, Khamgaon v/s Maharashtra Urban Co–operative Credit Society Ltd. ……………. Respondent Shakti Sanstha, Market Road Mehkar 443 301 PAN – AAAAM5777D Assessee by : None Revenue by : Shri Sandipkumar Salunke Date of Hearing – 03/02/2025 Date of Order – 25/02/2025 O R D E R PER V. DURGA RAO, J.M. These appeals by the Revenue are directed against the impugned o…

Rajura Nagari Sahakari Pat Sanstha Maryadit, Chandrapur vs. Office of the Income Tax Officer Ward 5, Chandrapur

ITA 483/NAG/2024[2016-17]Status: DisposedITAT Nagpur25 Feb 2025AY 2016-17

Bench: Shri V. Durga Rao

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Abhay Y. Marathe

Section 250Section 80P

…IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER SMC MATTER ITA no.483/Nag./2024 (Assessment Year : 2016–17) Rajura Nagari Sahakari Pat Sanstha Maryadit, Near Old Bus Stand ……………. Appellant Rajura, Chandrapur 442 905 PAN – AAAAR5884N v/s Income Tax Officer ……………. Respondent Ward–5, Chandrapur Assessee by : Shri Abhay Agrawal Revenue by : Shri Abhay Y. Marathe Date of Hearing – 04/02/2025 Date of Order – 25/02/2025 O R D E R This appeal by the assessee is emanating from the impugned order dated 02/05/2023, passed by the learned Commissioner of Income Tax (Ap…

B.S.N.L Employees Junior Co Operative Credit Society Limitd, Mumbai vs. ITO Ward 17(1)(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 30/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Feb 2025AY 2020-21

Bench: Shri Sandeep Singh Karhail & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Shekhar Patwardhan, CAFor Respondent: Shri Pravin Salunkhe, Sr. DR

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

…ction 80P(2)(d) of the Act on the basis that the Co- operative Bank is covered under the provisions of section 80P(4) of the Act. We find that the Hon'ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 123 taxmann.com 161/279 Taxman 75/431 ITR 1 while analysing the provisions of section 80P(4) of the Act held that section 80P(4) is a proviso to the main provision contained in section 80P(1) and (2) and excludes only Co-operative Banks, which are Co-operative Societies and also possesses a licence from RBI to do banking business. The Hon'ble Supreme Court further held that the limited objec…

Datta Sadan Co Operative Housing Society Limited, Mumbai vs. Income Tax Officer 22 1 6, Mumbai

The appeal of the appellant is allowed

ITA 86/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Feb 2025AY 2015-16

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am) Datta Sadan Cooperative Ito 22(1)(6) Housing Society Ltd. Piramal Chambers Build Arch Residency Vs. Lalbaug, Parel Kapad Bazar Road Mumbai-400 012. Mahim, Mumbai-400016. Pan : Aabad5480F Appellant Respondent

For Appellant: Shri Kiran UnavekarFor Respondent: Shri Ajay Arvind Wadke

Section 139(1)Section 143(1)(a)Section 154Section 80P(2)(d)

…duction u/s. 80P(2)(d) of the Act and order of Ld. CIT(A) is set aside. Moreover, now the issue is squarely covered by the 5 Datta Sadan Cooperative Housing Society Ltd. decision of Hon'ble Supreme Court in the case of Mavilayi Services Cooperative bank Ltd. (431 ITR 1)(SC) in favour of the appellant society when it was held that the appellant is entitled for deduction under section 80P(2)(d) of the Act. Thus the delay in filing the appeal was hereby condoned for the reasons mentioned above and the addition is also deleted on merits. 8. The appeal of the appellant is allowed. Order pronounced in the open Court…

Dream House Co Operative Housing Society Limited, Mumbai vs. ITO Ward 29(1)(3), Mumbai

ITA 201/MUM/2025[2016-17]Status: DisposedITAT Mumbai24 Feb 2025AY 2016-17

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am) Dream House Cooperative Ito Ward 29(1)(3) Housing Society Limited C-10/104, Bkc Plot No. 91, Sector 9 Vs. Bandra East Ulwe, Navi Mumbai Mumbai-400 051. 400 706. Pan : Aabad2668M Appellant Respondent

For Appellant: Shri Kiran UnavekarFor Respondent: Ms. Prajakta Arote

Section 80P(2)(d)

…TA No. 4675/Mum/2023). Finally, the Ld. AR of the appellant brought to the notice of this Bench that the issue is now fully covered in favour of the appellant by the decision of Hon'ble Supreme Court in the case of M/s. Mavilayi Service Cooperative Bank Ltd. (431 ITR 1)(SC) where it was held that the appellant is entitled for deduction u/s. 80P(2)(d) of the Act. 4. Ld. DR relied on the orders of the lower authorities, where the appellant-society was denied deduction u/s. 80P(2)(d) of the Act. 5. After hearing rival submissions, it is decided that the issue is squarely covered by the decision of Hon'ble Supreme…

Ekta Sahakari Patpedhi Maryadit, Virar vs. Income Tax Officer, Ward 4(5)/Thane, Thane

In the result, appeal by the assessee is allowed

ITA 104/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Feb 2025AY 2017-18

Bench: Shri Sandeep Singh Karhail & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri Bhupendra Shah, CAFor Respondent: Shri Kiran Unavekar, Sr. DR

Section 143(3)Section 234ASection 270ASection 80P(2)(a)Section 80P(2)(d)

Pragati Premises Co Op So Ltd, Mumbai vs. Assistant Commissioner of Income Tax Circle - 22(2), Mumbai

ITA 6358/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Feb 2025AY 2017-18

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am) Pragati Premises Co- Acit, Circle 22(2) Operative Society Ltd. Room No. 315 Society Office Pragati Vs. 3Rd Floor, Piramal Premises Chsl, 316 Chamber, Lal N.M. Joshi Marg, Lower Baugh, Parel Parel East Mumbai-400 012. Mumbai-400 011. Pan : Aaaap4642A Appellant Respondent

For Appellant: Shri P.D. ChouguleFor Respondent: Shri Dharan Gandhi

Section 234ASection 270ASection 80P(2)(d)

…T with the Grounds of appeal mentioned in page No. 1 of this order. 4. In this appeal, Ld. AR of the appellant has submitted that the issue is covered in favour of the appellant now after decision of Mavilayi Services Cooperative Bank Limited Vs. Ld. CIT(A) (431 ITR 1)(SC). The Ld. AR has filed copy of the decision rendered by the ITAT, Mumbai in the case of Murude Sahakari Patsanstha Maryadit Vs. ITO (ITA No. 901/Mum/2024 for A.Y. 2018-19) in which the ITAT relied on the decisions of Mavilayi Services Cooperative Bank Limited (supra) and gave relief to the appellant-society and held that the society is entitled…

Mayoor Co-Operative Housing Society Limited, Mumbai vs. Jurisdictional AO Ward 22(2)(1), Mumbai

ITA 5416/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Feb 2025AY 2021-22

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am) Mayoor Cooperative Ito Ward Housing Society Ltd. 22(2)(1) D Wing, Ground Floor Vs. Ao No. 91, M.T. N.L Road, Dadar Range Code 197 Maharashtra-400 028. Mumbai Pan : Appellant Respondent

For Appellant: Shri P.D. ChouguleFor Respondent: Shri Anil Sathe

Section 80P(2)(d)

…r book in which he relied on the decision rendered in his own case in A.Y. 2020-21, where the appellant society got relief and in this order, the coordinate Bench placed reliance of Hon'ble Supreme Court in the case of Mavilayi Services Cooperative Bank Ltd. (431 ITR 1)(SC). The appellant 2 Mayoor Cooperative Housing Society Ltd. society placed reliance on the decisions of Coordinate Benches viz., PCIT Vs. Ashvin Kumar Arban Cooperative Society Ltd. (168 taxman.com 314), Kaliandas Udyog Bhavan Premises Cooperative Society Ltd. (ITA No. 6547/Mum/2017), Ashok Tower “D” Cooperative Housing Society Ltd. Vs. ITO (16…

Edavilangu Service Co-Operative Bank No 3468, Thrissur vs. ITO, Ward-2(1), Thrissur

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 406/COCH/2024[AY 2020-2021]Status: DisposedITAT Cochin21 Feb 2025

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Smt. Leena Lal, Snr. ARFor Respondent: None

Section 2(1)Section 80Section 80PSection 80P(2)Section 80P(2)(a)

…t of Section 80(P)(4) is available to the societies similar to the appellant herein. Though, the correctness was doubted by the Full Bench of the Hon'ble High Court in Mavilayi Service Co- operative Bank Ltd. Vs. The Commissioner of Income Tax, Calicut [2021] 431 ITR 1 (SC) and connected cases, the same was setaside by the Apex Court was pleased to setaside the Order of the Hon'ble High Court by holding that once section 80P(4) is out of harm's way, all the assessees in are entitled to the benefit of the deduction contained in section 80P(2)(a)(i), notwithstanding that they may also be giving loans to their membe…

Edavilangu Service Co-Operative Bank Ltd No 3468, Thrissur vs. ITO, Ward-2(1), Thrissur

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 405/COCH/2024[2017-2018]Status: DisposedITAT Cochin21 Feb 2025AY 2017-2018

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Smt. Leena Lal, Snr. ARFor Respondent: None

Section 2(1)Section 80Section 80PSection 80P(2)Section 80P(2)(a)

Shri Shi vs. Ai Sahakari Patsanstha Limited, Mumbaivs.Income Tax Officer Ward 31(3)(4), Mumbai

Appeal of the assessee is partly allowed

ITA 4428/MUM/2024[2014-15]Status: DisposedITAT Mumbai21 Feb 2025AY 2014-15

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: NoneFor Respondent: Shri Asif Karmali, Sr. DR

Section 2(19)Section 80PSection 80P(1)Section 80P(2)(d)

…ection 80P(2)(d) of the Act on the basis that the Co-operative Bank is covered under the provisions of section 80P(4) of the Act. We find that the Hon?ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 123 taxmann.com 161/279 Taxman 75/431 ITR 1 while analysing the provisions of section 80P(4) of the Act held that section 80P(4) is a proviso to the main provision contained in section 80P(1) and (2) and excludes only Co-operative Banks, which are Co-operative Societies and also possesses a licence from RBI to do banking business. The Hon'ble Supreme Court further held that the limited objec…

Mhatre Palace Chsl, Borivali West vs. National E-Assessment Centre, Delhi, Mumbai

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

ITA 6394/MUM/2024[2023-24]Status: DisposedITAT Mumbai17 Feb 2025AY 2023-24

Bench: Hon’Ble Shri Sandeep Gosainvs. Ito – 42(1)(3) Mhatre Palace Chsl Kautilya Bhavan, Bkc 106 Mhatre Palace Chs Ltd Bandra E – 400 051. Ic Colony, Link Road, Borivali (W), Mumbai 400 013 Pan/Gir No. Aaaam9414D (Applicant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 80PSection 80P(2)Section 80P(2)(d)

…considered as Co- operative Society and Co-operative Bank is covered under the provisions of section 80P(4) of the Act. We find that the Hon'ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. v/s CIT, Calicut, [2021] 7 Mhatre Palace CHSL, Mumbai 431 ITR 1 (SC) while analysing the provisions of section 80P(4) of the Act held that section 80P(4) is a proviso to the main provision contained in section 80P(1) and (2) and excludes only Co- operative Banks, which are Co-operative Societies and also possesses a licence from RBI to do banking business. The Hon'ble Supreme Court further held that the limited…

The Suvarna Nagar Co Operative Housing Society Ltd, Mumbai vs. ITO, Ward, 34(3), Mumbai

In the result, the appeal by the assessee is allowed

ITA 11/MUM/2025[2019-20]Status: DisposedITAT Mumbai14 Feb 2025AY 2019-20

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalassessment Year : 2019-20

For Appellant: Ms. Parvathy Ganesh, CAFor Respondent: Shri Pravin Salunkhe, Sr. DR

Section 143(1)Section 250Section 80PSection 80P(2)(c)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL “H”(SMC) BENCH, MUMBAI BEFORE SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year : 2019-20 The Suvarna Nagar Co-operative Hsg. Society Ltd. Jai Hind Cub Building JVPD Scheme, 2nd Floor, N.S.Road, Vile Parle West, Mumbai-400057. ……………. Appellant PAN: AAAAS 4938 E v/s Asst. Director, Centralized Processing Centre/ ITO, Ward-34(3)(5), Kotilya Bhavan, Bandra Kurla Complex, ……………. Respondent Bandra, Mumbai Assessee by : Ms. Parvathy Ganesh, CA Revenue by : Shri Pravin Salunkhe, Sr. DR Date of Hearing – 11/02/2025 Date of Order –…

M/S. Lokamaleswaram Service Co-Operative Bank Ltd No.249, Thrissur vs. ITO, Ward 2(2), Thrissur

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

ITA 105/COCH/2025[2010-11]Status: DisposedITAT Cochin13 Feb 2025AY 2010-11

Bench: Shri Inturi Rama Rao

For Appellant: Sri.O.D.Sivadas, AdvocateFor Respondent: Smt.Leena Lal, Senior AR

Section 143(3)Section 148Section 80PSection 80P(2)Section 80P(2)(a)

…025. M/s.Lokamaleswaram SC.B Limited 4. Being aggrieved, the assessee is in appeal before me and submitted that in view of the decision of the Hon’ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd. & Ors. v. CIT & Anr. Reported in (2021) 431 ITR 1 (SC), which has overruled the reasoning of the AO. 5. I have heard the rival submissions and perused the material available on record. On a careful perusal of the orders of the AO as well as the CIT(A), it would be evident that the lower authorities have denied the deduction u/s.80P holding that the assessee is a co-operative bank. Undisputedly, t…

Acgl Bbd Employees Coop Credit Society Ltd, Bhuimpal Honda Sattari Goa vs. Income Tax Officer, Ward 1(1), Panaj, Panaji, Goa

The appeal of the assessee stands allowed

ITA 212/PAN/2024[201718]Status: DisposedITAT Panaji12 Feb 2025

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 212/Pan/2024 Assessment Year : 2017-18 Acgl Bbd Employees Co-Op. Credit Society, Ltd. Bhuimpal Honda, Sattari, Bhuimpal, North Goa. Pan : Aaaaa8278M . . . . . . . Applicant V/S Income Tax Officer Ward-1(1), Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr S J Kamat [‘Ld. Ar’] Revenue By : Mr Narendra Reddy [‘Ld. Dr’] Date Of Conclusive Hearing : 06/02/2025 Date Of Pronouncement : 12/02/2025 Order Per G. D. Padmahshali, Am; The Assessee Is In Appeal Against Din & Order No. Itba/Nfac/S/250/2024-25/1066146872(1) Dt. 27/06/2024 Passed U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] By The National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)/Nfac’ Hereinafter] Which In Turn Arisen Out Of Order Of Assessment Dt. 19/12/2019 Passed U/S 143(3) Of The Act By The Income Tax Officer, Ward-1(1), Panaji [‘Ld. Ao’ Hereinafter] For Assessment Year 2017-18 [‘Ay’ Hereinafter].

For Appellant: Mr S J Kamat [‘Ld. AR’]For Respondent: Mr Narendra Reddy [‘Ld. DR’]

Section 143(1)Section 143(2)Section 143(3)Section 250Section 80PSection 80P(2)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, PANAJI BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI G. D. PADMAHSHALI, ACCOUNTANT MEMBER ITA Nos. 212/PAN/2024 Assessment Year : 2017-18 ACGL BBD Employees Co-op. Credit Society, Ltd. Bhuimpal Honda, Sattari, Bhuimpal, North Goa. PAN : AAAAA8278M . . . . . . . Applicant V/s Income Tax Officer Ward-1(1), Panaji, Goa. . . . . . . . Respondent Appearances Assessee by : Mr S J Kamat [‘Ld. AR’] Revenue by : Mr Narendra Reddy [‘Ld. DR’] Date of conclusive Hearing : 06/02/2025 Date of Pronouncement : 12/02/2025 ORDER PER G. D. PADMAHSHALI, AM;…

Datta Sadan Co Operative Housing Society Limited, Mumbai vs. Income Tax Officer 22 1 6, Mumbai

In the result, the appeal by the assessee is allowed

ITA 87/MUM/2025[2021-22]Status: DisposedITAT Mumbai11 Feb 2025AY 2021-22

Bench: SHRI SANDEEP SINGH KARHAIL (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Ajay Arvind Wadke, ARFor Respondent: Shri Kiran Unavekar, Sr. DR

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

Kalliad Service Co-Operative Bank Ltd, Kannur vs. ITO, Ward-3, Kannur

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

ITA 678/COCH/2024[2017-18]Status: DisposedITAT Cochin10 Feb 2025AY 2017-18

Bench: Shri Inturi Rama Rao

For Appellant: ---- None ----For Respondent: Smt.Leena Lal, Senior AR

Section 143(3)Section 80P

…f the appeal on merits. 5. I have heard the rival submissions and perused the material available on record. I find that the issue is now settled by the judgment of the Hon’ble Supreme Court in the case of Mavilayi Service Co- operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC). Respectfully following the judgment of the Hon’ble Supreme Court, we direct the AO to allow the claim of the assessee. 6. In the result, the appeal filed by the assessee is allowed. Order pronounced on this 10th day of February, 2025. (Inturi Rama Rao) ACCOUNTANT MEMBER Cochin; Dated :10th February, 2025. Devadas G* 3 ITA No.678/Coch/2024. K…

Police Karmachari Sahakari Pat Sanstha Gondia, Gondia vs. Income Tax Officer Ward -2, Gondia

In the result, appeal by the assessee stands allowed

ITA 263/NAG/2024[2017-18]Status: DisposedITAT Nagpur05 Feb 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Abhay Y. Marathe

Section 143(3)

…te Act (b) be doing the specified activity of providing credit to its members. Business with non-members even if it is the specified activity is not eligible for deduction as held by the Apex Court in case of Mavilayi Service Co-operative Bank, Calicut (2021) 431 ITR 1 (SC). (c) entire income should be from the specified activity of credit to members. Income from other sources are not liable for the said deduction as held in case of Totgars Co-operative Sale Society Ltd. vs. Income-tax Officer (SC) (2010)188 Taxman 282 wherein the Apex Court held that interest income from deposits with banks cannot be held to inc…

Kadirur Service Co-Operative Bank Ltd, Kadirur vs. ITO, Ward-2, Kannur

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

ITA 872/COCH/2023[AY.2018-19]Status: DisposedITAT Cochin04 Feb 2025

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2018-19 Kadirur Service Co-Op. Bank Ltd. .......... Appellant Kadirur, Thalassery, Kannur 670642 [Pan: Aacak6088R] Vs. The Income Tax Officer .......... Respondent Ward - 2, Kannur Appellant By: Shri Arun Raj, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 23.01.2025 Date Of Pronouncement: 04.02.2025

For Appellant: Shri Arun Raj, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 80P

…ing aggrieved, an appeal was filed before the CIT(A), who vide the impugned order while allowing the claim for deduction u/s. 80P of the Act following the judgement of the Hon'ble Supreme Court in the case Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC) deleted the additions on account of provision for overdue interest and provision for bad and doubtful debts, have confirmed the addition on account of income tax refund of Rs. 44,40,300/-. 4. Being aggrieved, the assessee in appeal before the Tribunal in the present appeal. 5. The learned A.R. submitted that he CIT(A) ought not have confirme…

K6705 Bommanaickenpalayam Primary Agricultural Coop Credit Society Limited, Gobichettipalayam Taluk vs. The Income Tax Officer Ward 2(1), Erode

The appeal stand allowed for statistical purposes

ITA 2800/CHNY/2024[2017-2018]Status: DisposedITAT Chennai03 Feb 2025AY 2017-2018

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.2800/Chny/2024 (िनधा'रणवष' / Assessment Year: 2017-18) K6705 Bommanaickenpalayam Ito Primary Agricultural Co-Operative Ward-2(1), बनाम/ Credit Society Ltd. Erode. Vs. #R2-Nallapa Street, Periyar Nagar, Erode, Chennai-638 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabak-3912-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. R. Reshma (Advocate) - Ld.Ar " थ"कीओरसे/Respondent By : Shri Ashwin D. Gowda (Addl.Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 27-01-2025 घोषणाकीतारीख /Date Of Pronouncement : 03-02-2025

For Appellant: Ms. R. Reshma (Advocate) - Ld.ARFor Respondent: Shri Ashwin D. Gowda (Addl.CIT) - Ld. Sr. DR

Section 143(3)Section 37(1)Section 80P(2)(a)

…s.4.65 Lacs since the same were in the nature of provision for overdraft interest, gratuity and depreciation. 3. During appellate proceedings, the assessee relied on the decision of Hon’ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd. (123 Taxmann.com 161) and various other decisions. However, Ld. CIT(A) rejected the same on the ground that the assessee did not provide factual evidence regarding its income structure. The assessee failed to file the requisite documents and accordingly, the action of Ld. AO was upheld. No finding was rendered on disallowance u/s 37(1). 4. Considering the afo…