Mavilayi Service Co-operative Bank Ltd. v. CIT

The Principal Commissioner of Income Tax vs. The Kizhkkenalpathil Service Co-Operative Bank Ltd

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

…to the Revenue to seek review of the order made following the Circular. 4.1 The value in the appeal is less than the limit prescribed by CBDT Circular. The Supreme Court in the judgment reported in S.C.Naregal v Commissioner of Income Tax5 4 (2021) 431 ITR 1 (SC) 5(2019) 418 455 (SC) ITA No.25/2017 -7- has considered the effect of CBDT Circular and dismissed the appeal coming within the purport of CBDT Circular. The valuation of the subject appeal since is less than the limit stipulated by CBDT Circular, the judgment of Apex Court in S.C.Naregal (supra) is applicable to the appeal.…

The Principal Commissioner of Income Tax vs. M/S.Nallunakal Service Co-Operative Bank Ltd

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

…The principal question for decision is no more res integra in view of the principle laid down by the Apex Court in Mavilayi Service Co-operative Bank Ltd v. Commissioner of Income Tax4. The ancillary argument to bring the case under one or the 4 (2021) 431 ITR 1 (SC) ITA No.82/2019 -6- other exceptions is regarding the includable interest earned by the assessee/Society either from members or non-members or income from registered Co-operative Society or from Treasury Bank etc. Examined from any standpoint, it cannot be said that the consideration of the subject appeal by referring to the…

The Principal Commissioner of Income Tax vs. M/S. the Cherthala Govt.Servants Co-Operative Bank Ltd. No. 235. Cherthala

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

…to the Revenue to seek review of the order made following the Circular. 4.1 The value in the appeal is less than the limit prescribed by CBDT Circular. The Supreme Court in the judgment reported in S.C.Naregal v Commissioner of Income Tax5 4 (2021) 431 ITR 1 (SC) 5(2019) 418 455 (SC) ITA No.211/2019 -7- has considered the effect of CBDT Circular and dismissed the appeal coming within the purport of CBDT Circular. The valuation of the subject appeal since is less than the limit stipulated by CBDT Circular, the judgment of Apex Court in S.C.Naregal (supra) is applicable to the appeal.…

The Principal Commissioner of Income Tax vs. Valavoor Service Co-Operative Bank Limited

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

…to the Revenue to seek review of the order made following the Circular. 4.1 The value in the appeal is less than the limit prescribed by CBDT Circular. The Supreme Court in the judgment reported in S.C.Naregal v Commissioner of Income Tax5 4 (2021) 431 ITR 1 (SC) 5(2019) 418 455 (SC) ITA No.168/2019 -7- has considered the effect of CBDT Circular and dismissed the appeal coming within the purport of CBDT Circular. The valuation of the subject appeal since is less than the limit stipulated by CBDT Circular, the judgment of Apex Court in S.C.Naregal (supra) is applicable to the appeal.…

The Income Tax Officer, Ward - 1, Nipani vs. Shri Arihant Credit Souhard Sahakari Limited, Belgavi

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH : PANAJI BEFORE SHRI C.M. GARG, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.94 & 95/PAN/2018 Assessment Years: 2010-11 & 2011-12 ITO, Vs. Shri Arihant Credit Souhard Ward-1, Sahakari Ltd., Nipani. 346, Arihant, Patil Galli, A/P Borgaon, Taluka Chikodi, Distt. Belagavi. PAN: AABAS0813K (Appellant) (Respondent) Assessee by : Shri Ashok Mudnur, CA Revenue by : Shri Mayur Kamble, Sr. DR Date of Hearing : 15.06.2022 Date of Pronouncement : 01.09.2022 ORDER PER C.M. GARG, JM: These appeals have been filed by the assessee against the orders…

The Income Tax Officer, Ward - 1, Nipani vs. Shri Arihant Credit Souhard Sahakari Limited, Belgavi

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH : PANAJI BEFORE SHRI C.M. GARG, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.94 & 95/PAN/2018 Assessment Years: 2010-11 & 2011-12 ITO, Vs. Shri Arihant Credit Souhard Ward-1, Sahakari Ltd., Nipani. 346, Arihant, Patil Galli, A/P Borgaon, Taluka Chikodi, Distt. Belagavi. PAN: AABAS0813K (Appellant) (Respondent) Assessee by : Shri Ashok Mudnur, CA Revenue by : Shri Mayur Kamble, Sr. DR Date of Hearing : 15.06.2022 Date of Pronouncement : 01.09.2022 ORDER PER C.M. GARG, JM: These appeals have been filed by the assessee against the orders…

M/S Ravikiran Co-Operative Credit Society Limited, Belgundi, Belgavi vs. Income Tax Officer, Ward - 1(3), Belgavi

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

…IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH : PANAJI, GOA BEFORE SHRI CHANDRA MOHAN GARG, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA.No.436/PAN/2018 Assessment Year 2015-2016 M/s. Ravikiran Co- The Income Tax Officer, operative Credit Society Ward – 1 (3), Ltd., Belgundi, Dist. Belgavi. [vs. Belgavi. PIN 591 108. PAN AAAAR0468C (Appellant) (Respondent) For Assessee : Sh Shivanand Halbhavi, CA For Revenue : Sh Mayur Kamble, Sr. D.R. Date of Hearing : 17.06.2022 Date of Pronouncement : 01.09.2022 ORDER PER CHANDRA MOHAN GARG, J.M. This appeal has been filed by the assessee against th…

Shri Mallikarjun Urban Co-Operative Credit Society Ltd, Belgaum vs. Income Tax Officer, Ward - 1(4), Belagavi

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2015-16 Shri Mallikarjun Urban Ito, Ward-1(4), Co-Operative Credit Belagavi Society Ltd. Vs. A-P: Jugul, Tal: Athani, Dist: Belgaum-591252. Pan: Aaaas 5616 H (Appellant) (Respondent) Present For: Appellant By : Shri Shivanand Halbhavi, Ca Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 16.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Arising Out Of The Order Of Ld. Cit(A), Belgaum In Ita No.Cit(A)/Bgm/10167/2017-18 Dated 04.10.2018 Against The Order Passed By Ito, Ward-1(4), Belagavi U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The ‘Act’) Dated 14.11.2017. 2. The Grounds Taken By The Assessee In The Present Appeal Are Reproduced As Under:

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘PANAJI’ BENCH, PANAJI BEFORE SHRI CHANDRA MOHAN GARG, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2015-16 Shri Mallikarjun Urban ITO, WARD-1(4), Co-Operative Credit BELAGAVI Society Ltd. Vs. A-p: Jugul, Tal: Athani, Dist: Belgaum-591252. PAN: AAAAS 5616 H (Appellant) (Respondent) Present for: Appellant by : Shri Shivanand Halbhavi, CA Respondent by : Shri Mayur Kamble, Sr. DR Date of Hearing : 16.06.2022 Date of Pronouncement : 30.08.2022 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal by the assessee is arising out of the order…

The Adarsh Co-Op. Credit Society Limited., Belagavi vs. Income Tax Officer, Ward -1(2), Belagavi

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalita Nos.26 To 28/Pan/2019 Assessment Year: 2009-10, 2012-13 & 2013-14 The Adarsh Co-Op. Credit Ito, Ward-1(2), Society Ltd. Bagalkot Vs. A-P: Jugul, Tal: Athani, Dist: Belgaum-591252. Pan: Aaaas 5616 H (Appellant) (Respondent) Present For: Appellant By : Shri Pramod Vaidhya, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 17.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: These Appeals Filed By The Assessee Are Directed Against Different Orders Of Learned Commissioner Of Income Tax (Appeals) – Belagavi In Ita No. Cit(A)/Bgm/10349/2015-16, Cit(A)/Bgm/10518/2014-15 & Cit(A)/Bgm/10136/2015-16 All Dated 27.12.2018. The Assessments Were Framed By The Ito, Ward-1(2), Belgaum U/S 143(3) R.W.S. 254 Of The Income-Tax Act, 1961 (Hereinafter ‘The Act’), For The Assessment Year 2009-10 Vide Order Dated 27.12.2018 & For The Assessment Years 2012-13 & 2013-14 U/S 143(3) Of The Act Vide Order Dated 30.09.2014 & 24.08.2015. 2. The Only Issue In These Three Appeals Of Assessee Is As Regards To The Order Of Cit(A) Confirming The Denial Of Claim Of Deduction U/S 80P(2)(A)(I) Of The Act. The Assessee Has Raised Identical Grounds In All The Appeals & Hence, We Take The Facts & Grounds From Ita No. The Adarsh Co-Operative Credit Society Ltd. A.Y. 2009-10, 2012-13 & 2013-14 26/Pan/2019 For The Assessment Year 2009-10. The Relevant Grounds Raised By Assessee Are Reads As Under:

…d, assessee preferred appeal before the Tribunal. 5. Now, before us the ld. counsel for the assessee argued that the issue has been concluded by the decision of Hon’ble Supreme Court in the case of The Mavilayi Service Co-operative Bank Ltd., vs. CIT, (2021) 431 ITR 1 (SC), wherein the Hon’ble Supreme Court has considered the decision of Co-ordinate Bench of Supreme Court in the case of Citizen Co-operative Bank Ltd., (supra) wherein it has laid down certain principles which are culled out from the judgment as under:- (i) That section 80P of the IT Act is a benevolent provision, which was enacted by Parliament i…

The Adarsh Co-Op. Credit Society Limited., Belagavi vs. Income Tax Officer, Ward -1(2), Belagavi

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalita Nos.26 To 28/Pan/2019 Assessment Year: 2009-10, 2012-13 & 2013-14 The Adarsh Co-Op. Credit Ito, Ward-1(2), Society Ltd. Bagalkot Vs. A-P: Jugul, Tal: Athani, Dist: Belgaum-591252. Pan: Aaaas 5616 H (Appellant) (Respondent) Present For: Appellant By : Shri Pramod Vaidhya, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 17.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: These Appeals Filed By The Assessee Are Directed Against Different Orders Of Learned Commissioner Of Income Tax (Appeals) – Belagavi In Ita No. Cit(A)/Bgm/10349/2015-16, Cit(A)/Bgm/10518/2014-15 & Cit(A)/Bgm/10136/2015-16 All Dated 27.12.2018. The Assessments Were Framed By The Ito, Ward-1(2), Belgaum U/S 143(3) R.W.S. 254 Of The Income-Tax Act, 1961 (Hereinafter ‘The Act’), For The Assessment Year 2009-10 Vide Order Dated 27.12.2018 & For The Assessment Years 2012-13 & 2013-14 U/S 143(3) Of The Act Vide Order Dated 30.09.2014 & 24.08.2015. 2. The Only Issue In These Three Appeals Of Assessee Is As Regards To The Order Of Cit(A) Confirming The Denial Of Claim Of Deduction U/S 80P(2)(A)(I) Of The Act. The Assessee Has Raised Identical Grounds In All The Appeals & Hence, We Take The Facts & Grounds From Ita No. The Adarsh Co-Operative Credit Society Ltd. A.Y. 2009-10, 2012-13 & 2013-14 26/Pan/2019 For The Assessment Year 2009-10. The Relevant Grounds Raised By Assessee Are Reads As Under:

…d, assessee preferred appeal before the Tribunal. 5. Now, before us the ld. counsel for the assessee argued that the issue has been concluded by the decision of Hon’ble Supreme Court in the case of The Mavilayi Service Co-operative Bank Ltd., vs. CIT, (2021) 431 ITR 1 (SC), wherein the Hon’ble Supreme Court has considered the decision of Co-ordinate Bench of Supreme Court in the case of Citizen Co-operative Bank Ltd., (supra) wherein it has laid down certain principles which are culled out from the judgment as under:- (i) That section 80P of the IT Act is a benevolent provision, which was enacted by Parliament i…

The Adarsh Co-Op. Credit Society Limited., Belagavi vs. Income Tax Officer, Ward -1(2), Belagavi

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalita Nos.26 To 28/Pan/2019 Assessment Year: 2009-10, 2012-13 & 2013-14 The Adarsh Co-Op. Credit Ito, Ward-1(2), Society Ltd. Bagalkot Vs. A-P: Jugul, Tal: Athani, Dist: Belgaum-591252. Pan: Aaaas 5616 H (Appellant) (Respondent) Present For: Appellant By : Shri Pramod Vaidhya, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 17.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: These Appeals Filed By The Assessee Are Directed Against Different Orders Of Learned Commissioner Of Income Tax (Appeals) – Belagavi In Ita No. Cit(A)/Bgm/10349/2015-16, Cit(A)/Bgm/10518/2014-15 & Cit(A)/Bgm/10136/2015-16 All Dated 27.12.2018. The Assessments Were Framed By The Ito, Ward-1(2), Belgaum U/S 143(3) R.W.S. 254 Of The Income-Tax Act, 1961 (Hereinafter ‘The Act’), For The Assessment Year 2009-10 Vide Order Dated 27.12.2018 & For The Assessment Years 2012-13 & 2013-14 U/S 143(3) Of The Act Vide Order Dated 30.09.2014 & 24.08.2015. 2. The Only Issue In These Three Appeals Of Assessee Is As Regards To The Order Of Cit(A) Confirming The Denial Of Claim Of Deduction U/S 80P(2)(A)(I) Of The Act. The Assessee Has Raised Identical Grounds In All The Appeals & Hence, We Take The Facts & Grounds From Ita No. The Adarsh Co-Operative Credit Society Ltd. A.Y. 2009-10, 2012-13 & 2013-14 26/Pan/2019 For The Assessment Year 2009-10. The Relevant Grounds Raised By Assessee Are Reads As Under:

…d, assessee preferred appeal before the Tribunal. 5. Now, before us the ld. counsel for the assessee argued that the issue has been concluded by the decision of Hon’ble Supreme Court in the case of The Mavilayi Service Co-operative Bank Ltd., vs. CIT, (2021) 431 ITR 1 (SC), wherein the Hon’ble Supreme Court has considered the decision of Co-ordinate Bench of Supreme Court in the case of Citizen Co-operative Bank Ltd., (supra) wherein it has laid down certain principles which are culled out from the judgment as under:- (i) That section 80P of the IT Act is a benevolent provision, which was enacted by Parliament i…

Kalidas Co-Operative Credit Society Limited, Kamatgi, Bagalkot vs. Income Tax Officer, Ward - 1, Bagalkot

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2015-16 M/S. Kalidas Co- Ito, Ward-1, Operative Credit Bagalkot Society Ltd. Near Choudeshwari Vs. Temple, Kamatgi, Tal: Hungund, Dist: Bagalkot, Karnataka-587120. Pan: Aaaak 9788 L (Appellant) (Respondent) Present For: Appellant By : Shri Pramod Vaidhya, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 17.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Arising Out Of The Order Of Ld. Cit(A), Belagavi In Ita No.Cit(A)/Bgm/10172/2017-18 Dated 27.12.2018 Against The Order Passed By Ito, Ward-1, Bagalkot U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The ‘Act’) Dated 31.10.2017 For A.Y. 2015-16. 2. The Grounds Taken By The Assessee In The Present Appeal Are Reproduced As Under:

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘PANAJI’ BENCH, PANAJI BEFORE SHRI CHANDRA MOHAN GARG, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2015-16 M/S. KALIDAS CO- ITO, WARD-1, OPERATIVE CREDIT BAGALKOT SOCIETY LTD. Near Choudeshwari Vs. Temple, Kamatgi, Tal: Hungund, Dist: Bagalkot, Karnataka-587120. PAN: AAAAK 9788 L (Appellant) (Respondent) Present for: Appellant by : Shri Pramod Vaidhya, Advocate Respondent by : Shri Mayur Kamble, Sr. DR Date of Hearing : 17.06.2022 Date of Pronouncement : 30.08.2022 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal by the assessee i…

The Karnataka Karavali Urban Co-Operative Credit Society Limited, Athani vs. Income Tax Officer, Ward - 1 (4), Belgaum, Belagavi

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH : PANAJI BEFORE SHRI C.M. GARG, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos.457 & 458/PAN/2018 Assessment Years: 2012-13 & 2013-14 The Karnataka Karavali Urban Coop. Vs. ITO, Credit Society Ltd., Ward-1(1), CTS No.1173, Raviwar Peth, Belgaum. Sari Bazar, Athani, Distt. Belgaum - 591304 PAN: AAAK7952Q (Appellant) (Respondent) Assessee by : Shri S.M. Kedarshetti, Advocate Revenue by : Shri Mayur Kamble, Sr. DR Date of Hearing : 17.06.2022 Date of Pronouncement : 17.08.2022 ORDER PER C.M. GARG, JM: These appeals have been filed by the assessee…