State Bank Of India v. CIT

389 ITR 578High Court2016#60 most cited

What is State Bank Of India v. CIT authority for?

Income arising from a cooperative society's surplus funds invested in short-term deposits and securities is not attributable to the society's core activities and, therefore, is not eligible for exemption under Section 80P(2)(a)(i) of the Income-tax Act.

817

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2017 to 2026.

Also referred to as

State Bank of India v CIT · Section 80P(2)(a)(i) · Section 80P(2)(d) · cooperative society · investment income · exemption · short-term deposits · securities · surplus funds · not business income

Also reported as

72 Taxmann.com 64241 Taxmann 163

Sections most often in play

Section 80P(2)(d)Section 80P(2)(a)(i)Section 143(3)Section 80P(4)Section 80PSection 263Section 250Section 2(19)

Issues it is cited on

section 80(2)(d)section 80(p)(2)(d)section 2(19)section 80p(4)section 194a(3)(v)section 80p(2)(c)section 80p(2)(a)(iii)section 80p(1)section 80p(2)(d)section 194a(3)section 80p(2)(a)(i)section 80p(2)

Judgments citing State Bank Of India v. CIT

Primary Agricultural Credit Co-Operative Society Ltd, Konnur vs. Income Tax Officer, Ward - 1, Gokak

In the result, appeals of the assessee are allowed

ITA 111/PAN/2023[2020-21]Status: DisposedITAT Panaji20 Sept 2023AY 2020-21

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri Sanjay D Shirguppe, CAFor Respondent: Smt. Ashwini Hosmani, Sr.DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…n u/s. 80P(2)(a)(i) of the Act. The Hon‟ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Cooperative Federation of Housing Building Societies Ltd. 11 taxmann.com 448, the Hon‟ble Gujarat High Court in the case of State Bank of India Vs. CIT 389 ITR 578 (Guj.), the Hon‟ble Delhi High Court in the case of Mantola Cooperative Thrift & Credit Society Ltd. Vs. CIT 50 taxmann.com 278, the Hon‟ble Punjab & Haryana High Court in the case of CIT Vs. Punjab State Cooperative Agricultural Development Bank Ltd. 389 ITR 68 and the Hon‟ble Kolkata High Court in the case of CIT Vs. Southern Eastern Employees…

Primary Agricultural Credit Co-Operative Society Ltd, Konnur vs. Income Tax Officer, Ward - 1, Gokak

In the result, appeals of the assessee are allowed

ITA 110/PAN/2023[2018-19]Status: DisposedITAT Panaji20 Sept 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri Sanjay D Shirguppe, CAFor Respondent: Smt. Ashwini Hosmani, Sr.DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…n u/s. 80P(2)(a)(i) of the Act. The Hon‟ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Cooperative Federation of Housing Building Societies Ltd. 11 taxmann.com 448, the Hon‟ble Gujarat High Court in the case of State Bank of India Vs. CIT 389 ITR 578 (Guj.), the Hon‟ble Delhi High Court in the case of Mantola Cooperative Thrift & Credit Society Ltd. Vs. CIT 50 taxmann.com 278, the Hon‟ble Punjab & Haryana High Court in the case of CIT Vs. Punjab State Cooperative Agricultural Development Bank Ltd. 389 ITR 68 and the Hon‟ble Kolkata High Court in the case of CIT Vs. Southern Eastern Employees…

Primary Agricultural Credit Co-Operative Society Ltd, Konnur vs. Income Tax Officer, Ward - 1, Gokak

In the result, appeals of the assessee are allowed

ITA 109/PAN/2023[2017-18]Status: DisposedITAT Panaji20 Sept 2023AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri Sanjay D Shirguppe, CAFor Respondent: Smt. Ashwini Hosmani, Sr.DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…n u/s. 80P(2)(a)(i) of the Act. The Hon‟ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Cooperative Federation of Housing Building Societies Ltd. 11 taxmann.com 448, the Hon‟ble Gujarat High Court in the case of State Bank of India Vs. CIT 389 ITR 578 (Guj.), the Hon‟ble Delhi High Court in the case of Mantola Cooperative Thrift & Credit Society Ltd. Vs. CIT 50 taxmann.com 278, the Hon‟ble Punjab & Haryana High Court in the case of CIT Vs. Punjab State Cooperative Agricultural Development Bank Ltd. 389 ITR 68 and the Hon‟ble Kolkata High Court in the case of CIT Vs. Southern Eastern Employees…

The Bhandari Co-Op Credit Soiety Limited, Panaji vs. Income Tax Officer, Ward - 1(5), Panaji

In the result, appeals of the assessee are allowed

ITA 102/PAN/2023[2018-19]Status: DisposedITAT Panaji20 Sept 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri Amogh Arlekar, AdvocateFor Respondent: Smt. Ashwini Hosmani, Sr.DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…n u/s. 80P(2)(a)(i) of the Act. The Hon‟ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Cooperative Federation of Housing Building Societies Ltd. 11 taxmann.com 448, the Hon‟ble Gujarat High Court in the case of State Bank of India Vs. CIT 389 ITR 578 (Guj.), the Hon‟ble Delhi High Court in the case of Mantola Cooperative Thrift & Credit Society Ltd. Vs. CIT 50 taxmann.com 278, the Hon‟ble Punjab & Haryana High Court in the case of CIT Vs. Punjab State Cooperative Agricultural Development Bank Ltd. 389 ITR 68 and the Hon‟ble Kolkata High Court in the case of CIT Vs. Southern Eastern Employees…

The Bhandari Co-Op Credit Soiety Limited, Panaji vs. Income Tax Officer, Ward - 1(5), Panaji

In the result, appeals of the assessee are allowed

ITA 101/PAN/2023[2017-18]Status: DisposedITAT Panaji20 Sept 2023AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri Amogh Arlekar, AdvocateFor Respondent: Smt. Ashwini Hosmani, Sr.DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…n u/s. 80P(2)(a)(i) of the Act. The Hon‟ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Cooperative Federation of Housing Building Societies Ltd. 11 taxmann.com 448, the Hon‟ble Gujarat High Court in the case of State Bank of India Vs. CIT 389 ITR 578 (Guj.), the Hon‟ble Delhi High Court in the case of Mantola Cooperative Thrift & Credit Society Ltd. Vs. CIT 50 taxmann.com 278, the Hon‟ble Punjab & Haryana High Court in the case of CIT Vs. Punjab State Cooperative Agricultural Development Bank Ltd. 389 ITR 68 and the Hon‟ble Kolkata High Court in the case of CIT Vs. Southern Eastern Employees…

The Marol Co-Operative Industrial Estate Ltd, Mumbai vs. ACIT, Circle-25(1), Mumbai

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

ITA 2027/MUM/2023[2017-18]Status: DisposedITAT Mumbai13 Sept 2023AY 2017-18

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry: A.Y : 2017-18 The Marol Co-Operative Industrial Vs. Asstt. Commissioner Of Income Estate Limited Tax, Circle 25(1), Mumbai. Marol Bhavan, Mathurdas (Respondent) Vasanji Road, J.B. Nagar, Andheri (E), Mumbai 400 059. Pan : Aaaat0060A (Appellant)

For Appellant: Shri Kartik NatrajanFor Respondent: Smt. Mahita Nair
Section 80PSection 80P(2)(d)

…Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon‟ble High Court of Gujarat in the Kaliandas Udyog Bhavan Premises Co- op Society Ltd. vs. ITO - A.Y. 2014-15 10 ITA No.6547/MUM/2017 case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had also held that the interest income earned by the assessee on its investments held with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, as had been relied upon by the ld. A.R, also makes it clear beyond any scope of doub…

M/S Ravikiran Co-Operative Credit Society Limited, Belagavi vs. Principal Commissioner of Income Tax, Hubli

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

ITA 94/PAN/2023[2018-19]Status: DisposedITAT Panaji08 Sept 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhurysl.

For Appellant: NoneFor Respondent: Shri Prabhakar Anand DJ
Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

…Rs.11,50,472/- by placing reliance on the decision of the Hon’ble Karnataka High Court in the case of PCIT vs. Totagars Co- operative Sale Society, 395 ITR 611 (Kar.), the decision of the Hon’ble Gujarat High Court in the case of State Bank of India vs. CIT, 389 ITR 578 (Guj.) and the decision of the Hon’ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Co-op. Agricultural Development Bank Ltd., 389 ITR 607 (P&H). 5. Being aggrieved by the above order of assessment, an appeal was filed before the NFAC, who vide impugned order confirmed the action of the Assessing Officer. 6. Being aggrieved, th…

M/S Ravikiran Co-Operative Credit Society Limited, Belagavi vs. National E - Assessment Centre, Delhi

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

ITA 93/PAN/2023[2018-19]Status: DisposedITAT Panaji08 Sept 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhurysl.

For Appellant: NoneFor Respondent: Shri Prabhakar Anand DJ
Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

…Rs.11,50,472/- by placing reliance on the decision of the Hon’ble Karnataka High Court in the case of PCIT vs. Totagars Co- operative Sale Society, 395 ITR 611 (Kar.), the decision of the Hon’ble Gujarat High Court in the case of State Bank of India vs. CIT, 389 ITR 578 (Guj.) and the decision of the Hon’ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Co-op. Agricultural Development Bank Ltd., 389 ITR 607 (P&H). 5. Being aggrieved by the above order of assessment, an appeal was filed before the NFAC, who vide impugned order confirmed the action of the Assessing Officer. 6. Being aggrieved, th…

M/S Ravikiran Co-Operative Credit Society Limited, Belagavi vs. The Income Tax Officer, Ward - 3, Belagavi

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

ITA 92/PAN/2023[2017-18]Status: DisposedITAT Panaji08 Sept 2023AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhurysl.

For Appellant: NoneFor Respondent: Shri Prabhakar Anand DJ
Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

…Rs.11,50,472/- by placing reliance on the decision of the Hon’ble Karnataka High Court in the case of PCIT vs. Totagars Co- operative Sale Society, 395 ITR 611 (Kar.), the decision of the Hon’ble Gujarat High Court in the case of State Bank of India vs. CIT, 389 ITR 578 (Guj.) and the decision of the Hon’ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Co-op. Agricultural Development Bank Ltd., 389 ITR 607 (P&H). 5. Being aggrieved by the above order of assessment, an appeal was filed before the NFAC, who vide impugned order confirmed the action of the Assessing Officer. 6. Being aggrieved, th…

Shri Vardhaman Urban Credit Souharda Sahakari Niyamit, Kudchi vs. Income Tax Officer, Ward - 1, Belagavi

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

ITA 91/PAN/2023[2017-18]Status: DisposedITAT Panaji08 Sept 2023AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.91/Pan/2023 िनधा"रण वष" / Assessment Year : 2017-18 Shri Vardhaman Urban Vs. Ito, Ward-1, Belgaum. Credit Souharda Sahakari Niyamit, Post- Kudchi, Tal- Raibag, Dist.- Belgaum, Karnataka- 591005. Pan : Aaaas5599R Appellant Respondent S.A. No.07/Pan/2023 (Arising Out Of Ita No.91/Pan/2023) िनधा"रण वष" / Assessment Year : 2017-18 Shri Vardhaman Urban Vs. Ito, Ward-1, Belgaum. Credit Souharda Sahakari Niyamit, Post- Kudchi, Tal- Raibag, Dist.- Belgaum, Karnataka- 591005. Pan : Aaaas5599R Appellant Respondent Assessee By : Shri U. G. Ammangi Revenue By : Shri Ashwini D. Hosmani Date Of Hearing : 04.09.2023 Date Of Pronouncement : 08.09.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of The National Faceless Appeal Centre, Delhi [‘Nfac’] Dated

For Appellant: Shri U. G. AmmangiFor Respondent: Shri Ashwini D. Hosmani
Section 143(3)Section 21Section 80PSection 80P(2)(a)Section 80P(2)(d)

…on u/s 80P(2)(a)(i) of the Act. The Hon’ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Cooperative Federation of Housing Building Societies Ltd. 11 taxmann.com 448, the Hon’ble Gujarat High Court in the case of State Bank of India vs. CIT 389 ITR 578 (Guj.), the Hon’ble Delhi High Court in the case of Mantola Co- operative Thrift & Credit Society Ltd. vs. CIT 50 taxmann.com 278, the Hon’ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Cooperative Agricultural Development Bank Ltd. 389 6 S.A. No.07/PAN/2023 ITR 68 and the Hon’ble Kolkata High Court in the case of CIT vs. So…

M/S Sumangala Credit Co-Op. Society Ltd., Bantawal vs. Income Tax Officer, Ward-2(3), Mangaluru.

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

ITA 383/BANG/2023[2017-18]Status: DisposedITAT Bangalore07 Sept 2023AY 2017-18

Bench: Shri Chandra Poojari & Ms. Madhumita Royassessment Year: 2017-18

For Appellant: Shri Ravish Rao, A.RFor Respondent: Dr. Nischal, D.R
Section 56Section 80P(1)Section 80P(2)(a)Section 80P(2)(d)

…2)(d). At the same time, we find, that the Hon'ble Karnataka High Court in the case of PCIT & Anr. vs. Totagars Cooperative Sale Society reported in (2017) 392 ITR 74 and Hon’ble Gujarat High Court in the case of State Bank Of India Vs. CIT reported in (2016) 389 ITR 578, held, that the interest income earned by a co-operative society on its investments held with a cooperative bank would be eligible for claim of deduction under Sec.80P(2)(d) of the Act. Sumangala Credit Co-Operative Society, Bantwal Page 4 of 6 9.3 At this juncture, we respectfully following the view taken by the Hon'ble Karnataka High Court in t…

Gramin Sewa Sahakari Samiti Maryadit, Lawan, Baloda Bazar vs. Income Tax Officer, Ward-Bhatapara, Baloda Bazar

ITA 208/RPR/2023[2017-18]Status: DisposedITAT Raipur05 Sept 2023AY 2017-18

Bench: Shri Ravish Sood

For Appellant: None (Written Submissions)For Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 250Section 80P(2)Section 80P(2)(d)

…We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon’ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co- operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-secti…

Gramin Sewa Sahakari Samiti Maryadit, Lawan, Baloda Bazar vs. Income Tax Officer, Ward-Bhatapara, Baloda Bazar

ITA 207/RPR/2023[2016-17]Status: DisposedITAT Raipur05 Sept 2023AY 2016-17

Bench: Shri Ravish Sood

For Appellant: None (Written Submissions)For Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 250Section 80P(2)Section 80P(2)(d)

…We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon’ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co- operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-secti…

Gramin Sewa Sahakari Samiti Maryadit, Lawan, Baloda Bazar vs. Income Tax Officer, Ward-Bhatapara, Baloda Bazar

ITA 206/RPR/2023[2015-16]Status: DisposedITAT Raipur05 Sept 2023AY 2015-16

Bench: Shri Ravish Sood

For Appellant: None (Written Submissions)For Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 250Section 80P(2)Section 80P(2)(d)

…We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon’ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co- operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-secti…

Gramin Sewa Sahakari Samiti Maryadit, Lawan, Baloda Bazar vs. Income Tax Officer, Ward-Bhatapara, Baloda Bazar

ITA 205/RPR/2023[2013-14]Status: DisposedITAT Raipur05 Sept 2023AY 2013-14

Bench: Shri Ravish Sood

For Appellant: None (Written Submissions)For Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 250Section 80P(2)Section 80P(2)(d)

…We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon’ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co- operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-secti…

Gramin Sewa Sahakari Samiti Maryadit, Khauna, Raipur vs. Income Tax Officer-1(2), Raipur

ITA 204/RPR/2023[2016-17]Status: DisposedITAT Raipur05 Sept 2023AY 2016-17

Bench: Shri Ravish Sood

For Appellant: None (Written Submissions)For Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 250Section 80P(2)Section 80P(2)(d)

…We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon’ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co- operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-secti…

Gramin Sewa Sahakari Samiti Maryadit, Khauna, Raipur vs. Income Tax Officer-1(2), Raipur

ITA 203/RPR/2023[2013-14]Status: DisposedITAT Raipur05 Sept 2023AY 2013-14

Bench: Shri Ravish Sood

For Appellant: None (Written Submissions)For Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 250Section 80P(2)Section 80P(2)(d)

…We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon’ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co- operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-secti…

Gramin Sewa Sahakri Samiti Maryadit, Dharsiwa, Raipur vs. Income Tax Officer 1(2), Raipur

ITA 202/RPR/2023[2012-13]Status: DisposedITAT Raipur05 Sept 2023AY 2012-13

Bench: Shri Ravish Sood

For Appellant: None (Written Submissions)For Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 250Section 80P(2)Section 80P(2)(d)

…We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon’ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co- operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-secti…

Visa Bharati Co-Operative Credit Society Limited., Santiniketan vs. ITO, Ward-3($), Suri, Birbhum, Suri West-Bengal

In the result, appeal of the assessee is allowed

ITA 429/KOL/2023[2015-16]Status: DisposedITAT Kolkata28 Aug 2023AY 2015-16

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2015-16

For Appellant: Shri Miraj D. Shah, AdvocateFor Respondent: Shri Sailendra Kumar Pandey, Addl. CIT, Sr.DR
Section 143(3)Section 263Section 80(2)(a)Section 80PSection 80P(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL “(SMC)” BENCH KOLKATA BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2015-16 Visva Bharati Co-operative Credit Income-tax Officer, Ward- Society Limited, 3(4), Suri, Birbhum Vs. Santiniketan, Birbhum, West Bengal-731235 (PAN: AAAAV8587G) (Appellant) (Respondent) Present for: Appellant by : Shri Miraj D. Shah, Advocate Respondent by : Shri Sailendra Kumar Pandey, Addl. CIT, Sr.DR Date of Hearing : 15.06.2023 Date of Pronouncement : 28.08.2023 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assesse…

The Tata Employees Co-Operative Credit Society Limited, Mumbai vs. Principle Commissioner of Income Tax (PCIT)-17, Mumbai

ITA 1864/MUM/2023[2018-2019]Status: DisposedITAT Mumbai28 Aug 2023AY 2018-2019

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2018-19

For Appellant: Ms. Ridhima Ramnani, A.RFor Respondent: Shri. Biswanath Das- CIT DR
Section 143Section 143(3)Section 2Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon‟ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-sectio…