What is Subramanian and Anr. v. Siemens India Ltd. and Anr. authority for?

When there is a conflict between the decisions of non-jurisdictional High Courts, the view that favors the assessee should be preferred.

How many judgments cite Subramanian and Anr. v. Siemens India Ltd. and Anr.?

541 judgments on BharatTax cite Subramanian and Anr. v. Siemens India Ltd. and Anr. (156 ITR 11), spanning 2015 to 2026.

Which sections of the Income Tax Act does Subramanian and Anr. v. Siemens India Ltd. and Anr. come up under?

It is most often cited in judgments turning on Section 80P(2)(d), Section 143(3), Section 80P(4), Section 80P(2)(a)(i), Section 263, Section 143(1).

Subramanian and Anr. v. Siemens India Ltd. and Anr. (156 ITR 11)

Income Tax Officer Ward-2, Ahmednagar vs. Goreshwar Gramin Bigar Sheti Sahakari Pat Sanstha Maryadit, Parner Dist. Ahmednagar

Appeal is dismissed in above terms

ITA 1191/PUN/2023[2020-21]Status: DisposedITAT Pune03 Jun 2024AY 2020-21

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Ramnath P Murkunde

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “A” BENCH : PUNE [VIRTUAL HEARING] BEFORE SHRI RAMA KANTA PANDA, VICE PRESIDENT AND SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER I.T.A.No.1191/PUN./2023 [E-APPEAL] Assessment Year 2020-2021 The Income Tax Officer, Goreshwar Gramin Bigar Ward-2, Aayakar Bhavan, Sheti Sahakari Pat Sanstha Behind Natraj Hotel, Maryadit, Parner, Goregaon, Aurangabad Road, Ahmednagar, Maharashtra. vs. Ahmednagar-414 001 PIN – 414 103 Maharashtra. PAN AAATG7073K (Appellant) (Respondent) For Revenue : Shri Ramnath P Murkunde For Assessee : -None- Date of Hearing : 03.06.2024 Date of Pronouncem…

Income Tax Officer, Ward 10(1), Pune, Akurdi vs. Shri Bhairavnat Gramin Bigarsheti Patsanstha Maryadig, Landewadi

Appeal is dismissed in above

ITA 252/PUN/2024[2017]Status: DisposedITAT Pune28 May 2024

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: -None-For Respondent: Shri Ramnath P. Murkunde

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “A” BENCH : PUNE : [HYBRID HEARING] BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI GD PADMAHSHALI, , ACCOUNTANT MEMBER I.T.A.No.252/PUN./2024 [E-APPEAL] Assessment Year 2017-2018 M/s. Shri Bhairavnath The Income Tax Officer, Gramin Bigarsheti Sahakari Ward-10(1), Patsanstha Maryadit, Pratyakshakar Bhavan, vs. At Post Landewadi, Near Akurdi Railway Chinchwadi, Tal-Ambegaon, Station, Pune – 411 044. Pune – 410 503. Maharashtra. Maharashtra. (Appellant) (Respondent) For Revenue : Shri Ramnath P. Murkunde For Assessee : -None- Date of Hearing : 27.05.2024 Date…

Rajat Apartments Co-Op. Housing Society Ltd., Mumbai vs. ACIT Circle 19(3), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 4329/MUM/2023[2021-22]Status: HeardITAT Mumbai27 May 2024AY 2021-22

Bench: Shri Girish Agrawal & Shri Sunil Kumar Singh

For Appellant: Shri Jayesh Dadia, C.A RevenueFor Respondent: Smt. Mahita Nair, Sr. DR

Section 143(1)Section 154Section 56Section 80P(2)(d)

…luded that a co- operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. v. Siemens India Ltd. and Anr [1983] 36 CTR 197/[1985] 156 ITR 11/[1983] 15 Taxman 594 (Bombay), where there is a conflict between the decisions of non-jurisdictional High Court's, then a view which is in favour of the assessee is to be preferred as against that taken against him. Thus, taking support from the aforesaid judicial pronouncement of the Hon'ble High Court of jurisdiction, we respectfully follow the…

Rajat Apartments Co.Op. Housing Society, Mumbai vs. ACIT Circle 19(3), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 4328/MUM/2023[2020-21]Status: HeardITAT Mumbai27 May 2024AY 2020-21

Bench: Shri Girish Agrawal & Shri Sunil Kumar Singh

For Appellant: Shri Jayesh Dadia, C.A RevenueFor Respondent: Smt. Mahita Nair, Sr. DR

Section 143(1)Section 154Section 56Section 80P(2)(d)

…luded that a co- operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. v. Siemens India Ltd. and Anr [1983] 36 CTR 197/[1985] 156 ITR 11/[1983] 15 Taxman 594 (Bombay), where there is a conflict between the decisions of non-jurisdictional High Court's, then a view which is in favour of the assessee is to be preferred as against that taken against him. Thus, taking support from the aforesaid judicial pronouncement of the Hon'ble High Court of jurisdiction, we respectfully follow the…

Sadhana Sahakari Patpedhi Limited, Vasai, Palghar vs. CIT(A), NFAC, Delhi

ITA 57/MUM/2024[2020-21]Status: DisposedITAT Mumbai22 May 2024AY 2020-21

For Appellant: Shri Unmesh NarvekarFor Respondent: Dr. Kishor Dhule

Section 143Section 143(1)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)Section 80P(4)

…Court had concluded that a co-operative society would not be entitled to claim of deduction under Section 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-jurisdictional High Court’s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Thus, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by the Hon'bl…

Sadhana Sahakari Patpedhi Limited, Palghar vs. CIT(A), NFAC, Delhi

ITA 56/MUM/2024[2018-19]Status: DisposedITAT Mumbai22 May 2024AY 2018-19

For Appellant: Shri Unmesh NarvekarFor Respondent: Dr. Kishor Dhule

Section 143Section 143(1)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)Section 80P(4)

…Court had concluded that a co-operative society would not be entitled to claim of deduction under Section 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-jurisdictional High Court’s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Thus, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by the Hon'bl…

ITO-26(2)(1), Mumbai vs. Sangli Vaibhav Co Operative Credit Society Limited, Mumbai

ITA 3770/MUM/2023[2018-19]Status: DisposedITAT Mumbai22 May 2024AY 2018-19

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ketan L. VajaniFor Respondent: Dr. Kishor Dhule

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

…Court had concluded that a co-operative society would not be entitled to claim of deduction under Section 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-jurisdictional High Court’s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Thus, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by the Hon'bl…

ITO-26(2)(1), Mumbai vs. Sangli Vaibhav Co Operative Credit Society Limited, Mumbai

ITA 3769/MUM/2023[2017-18]Status: DisposedITAT Mumbai22 May 2024AY 2017-18

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ketan L. VajaniFor Respondent: Dr. Kishor Dhule

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

…Court had concluded that a co-operative society would not be entitled to claim of deduction under Section 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-jurisdictional High Court’s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Thus, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by the Hon'bl…

ITO-26(2)(1), Mumbai vs. Sangli Vaibhav Co Operative Credit Society Limited, Mumbai

ITA 3766/MUM/2023[2020-21]Status: DisposedITAT Mumbai22 May 2024AY 2020-21

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ketan L. VajaniFor Respondent: Dr. Kishor Dhule

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

…Court had concluded that a co-operative society would not be entitled to claim of deduction under Section 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-jurisdictional High Court’s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Thus, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by the Hon'bl…

Kundalika Nagari Sahakari Pathsanstha Maryadit, Roha vs. Income Tax Officer, Ward-1, Panvel

Appeal is allowed in above terms

ITA 288/PUN/2024[2016-17]Status: DisposedITAT Pune15 May 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

For Appellant: CA Ajinkya M VaishampayanFor Respondent: Shri Ramnath P Murkunde

Section 143(3)Section 147Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “A” BENCH : PUNE [THROUGH HYBRID HEARING] BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER I.T.A.No.288/PUN./2024 Assessment Year 2016-2017 Kundalika Nagari Sahakari Patsanstha The Income Tax Officer, Maryadit, Ground Floor, Ward-1, Aayakar Bhavan, Varun Apartment, Near Plot No.2/2A, Sector-17, vs. Bhate Vachanalaya, Opposte Khanda Colony, Sonar Ali, ROHA-402 109. New Panvel – 410 206. Maharashtra. Maharashtra. PAN AACAK6478R (Appellant) (Respondent) For Assessee : CA Ajinkya M Vaishampayan For Revenue : Shri Ramnath P Mur…

Usha Janakalyan Nagar Chs Ltd, Mumbai vs. The Income Tax Officer-30(1)(1), Mumbai

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

ITA 4695/MUM/2023[2014-15]Status: DisposedITAT Mumbai15 May 2024AY 2014-15

Bench: Shir Pavan Kumar Gadale & Shri Girish Agrawalusha Janakalyan Nagar Vs. Ito-30(1)(1), Chs Ltd, Kautilya Bhavan, 211, Bkc, Bandra (E), Kharodi,Marveroad, Mumbai-400051. Malad (W), Mumbai-400095. Pan/Gir No. : Aaaau1039J Appellant .. Respondent Appellant By : Shri. Kunal Lunawat.Ar Respondent By : Ms. Rajeswari Menon, Sr.Dr Date Of Hearing 15.05.2024 Date Of Pronouncement 16.05.2024 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi/Cit (A) Passed U/Sec 154 & U/Sec 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. Kunal Lunawat.ARFor Respondent: Ms. Rajeswari Menon, Sr.DR

Section 143Section 143(1)Section 154Section 250Section 80Section 80PSection 80P(2)(d)

…ty on its investments held with a cooperative bank would be eligible for claim of deduction under Sec. 80P(2) (d) of the Act. We find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of nonjurisdictional High Court's, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon'ble High Court of jurisdiction, we respectfully follow the view taken by the…

Ganesh Vyapari Gramin Bigarsheti Sahakari Patsanstha Maryadit, Sangli vs. Income Tax Officer, Ward-2, Sangli

Appeal is allowed in above terms

ITA 643/PUN/2024[2018-19]Status: DisposedITAT Pune14 May 2024AY 2018-19

Bench: Shri Satbeer Singh Godara

For Appellant: Shri S.N. PuranikFor Respondent: Shri Kalpesh Kumar Rupavatiya

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “SMC” BENCH : PUNE BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER I.T.A.No.643/PUN./2024 Assessment Year 2018-2019 Ganesh Vyapari Gramin Bigarsheti Sahakari The Income Tax Officer, Patsanstha Maryadit, Ward-2, Aayakar Bhawan, Mangalwar Peth, A/P- Bhinge Bldg., Miraj Road, vs. Jath, Tal-Jath, Dist. Opp. Z.P. SANGLI – 416 416. Maharashtra. Sangli. PIN – 416 404. PAN AAAAG1138N (Appellant) (Respondent) For Assessee : Shri S.N. Puranik For Revenue : Shri Kalpesh Kumar Rupavatiya Date of Hearing : 10.05.2024 Date of Pronouncement : 14.05.2024 ORDER This assessee’s appe…

Balaji Shrushti Chs Ltd, Panvel vs. ITO, Ward - 1, Panvel

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

ITA 524/PUN/2024[2021-22]Status: DisposedITAT Pune14 May 2024AY 2021-22

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.523 & 524/Pun/2024 िनधा"रण वष" / Assessment Years : 2020-21 & 2021-22 Balaji Shrushti Chs Ltd., Vs. Ito, Ward-1, Panvel. Ground Floor, Plot No.3, Sector 19, New Panvel Navi Mumbai- 410206. Pan : Aaaab8345G Appellant Respondent Assessee By : None Revenue By : Shri Manoj Tripathi Date Of Hearing : 29.04.2024 Date Of Pronouncement : 14.05.2024 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Common Order Dated 19.02.2024 Passed By Ld Cit(A) Addl/Jcit (A), Prayagraj For The Assessment Years 2020-21 & 2021-22 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Assessee In Ita No.523/Pun/2024 For The Assessment Year 2020-21 Are Stated Herein.

For Appellant: NoneFor Respondent: Shri Manoj Tripathi

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA Nos.523 & 524/PUN/2024 िनधा"रण वष" / Assessment Years : 2020-21 & 2021-22 Balaji Shrushti CHS Ltd., Vs. ITO, Ward-1, Panvel. Ground Floor, Plot No.3, Sector 19, New Panvel Navi Mumbai- 410206. PAN : AAAAB8345G Appellant Respondent Assessee by : None Revenue by : Shri Manoj Tripathi Date of hearing : 29.04.2024 Date of pronouncement : 14.05.2024 आदेश / ORDER PER VINAY BHAMORE, JM: Both the above captioned appeals filed by the assessee are directed a…

Balaji Shrushti Chs Ltd, New Panvel vs. ITO, Ward - 1, Panvel

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

ITA 523/PUN/2024[2020-21]Status: DisposedITAT Pune14 May 2024AY 2020-21

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.523 & 524/Pun/2024 िनधा"रण वष" / Assessment Years : 2020-21 & 2021-22 Balaji Shrushti Chs Ltd., Vs. Ito, Ward-1, Panvel. Ground Floor, Plot No.3, Sector 19, New Panvel Navi Mumbai- 410206. Pan : Aaaab8345G Appellant Respondent Assessee By : None Revenue By : Shri Manoj Tripathi Date Of Hearing : 29.04.2024 Date Of Pronouncement : 14.05.2024 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Common Order Dated 19.02.2024 Passed By Ld Cit(A) Addl/Jcit (A), Prayagraj For The Assessment Years 2020-21 & 2021-22 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal Of The Assessee In Ita No.523/Pun/2024 For The Assessment Year 2020-21 Are Stated Herein.

For Appellant: NoneFor Respondent: Shri Manoj Tripathi

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA Nos.523 & 524/PUN/2024 िनधा"रण वष" / Assessment Years : 2020-21 & 2021-22 Balaji Shrushti CHS Ltd., Vs. ITO, Ward-1, Panvel. Ground Floor, Plot No.3, Sector 19, New Panvel Navi Mumbai- 410206. PAN : AAAAB8345G Appellant Respondent Assessee by : None Revenue by : Shri Manoj Tripathi Date of hearing : 29.04.2024 Date of pronouncement : 14.05.2024 आदेश / ORDER PER VINAY BHAMORE, JM: Both the above captioned appeals filed by the assessee are directed a…

Income Tax Officer, Mumbai vs. Larsen Toubro Kamgar Sahakari Patpedni Marydit, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 4446/MUM/2023[2018-19]Status: DisposedITAT Mumbai14 May 2024AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 143(3)Section 809(2)(d)Section 80PSection 80P(2)(d)

…395 ITR 611 (karn) and pr.cit vs Totagars co-operative sale society (2017) 392 ITR 74 (Karn) are entirely different? 3. Whether on the facts and circumstances of the case in law, the Hon’ble ITAT erred in relying on k. Subramanian vs Siemens India Ltd. (1985) 156 ITR 11 (Bombay), without appreciating that there is no inherent conflict between the judgements of Hon'ble high court of Karnataka in cases pr.cit vs Totagars co-operative sale society (2017) 395 ITR 611 (Karn) and pr.cit vs Totagars co-operative (2017) 392 ITR (Karn) as different questions of law have been decided upon by the Hon'ble Karnataka court? 4…

Vithal Court Apartments Chs Ltd, Mumbai vs. Assistant Director Income Tax, CPC, Bangaluru, Mumbai

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

ITA 4279/MUM/2023[2021-22]Status: DisposedITAT Mumbai14 May 2024AY 2021-22

Bench: Shri B.R. Baskaranassessment Year 2021-22 Vithal Court Apartments Chs Ltd. 151, August Kranti Marg, Kemps Corner, Mumbai – 400 036 Pan:Aaaav-3708-M - Appellant Vs. Adit, Cpc,Bangaluru Bangaluru. - Respondent Assessee By : Shri Sameer G. Dalal Revenue By : Shri Suni Mathew, Sr.Dr Date Of Hearing : 02/05/2024 Date Of Pronouncement : 14/05/2024 O R D E R

For Appellant: Shri Sameer G. DalalFor Respondent: Shri Suni Mathew, Sr.DR

Section 80PSection 80P(2)(d)

…a co-operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. 5 Assessment Year 2021-22 Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-jurisdictional High Court’s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Thus, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by the Hon'bl…

The Navyug Co-Operative Housing Society Ltd., Mumbai vs. DCIT 32(1), Mumbai

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

ITA 14/MUM/2024[2015-16]Status: DisposedITAT Mumbai10 May 2024AY 2015-16

Bench: Shir Pavan Kumar Gadale & Ms Padmavathy Sthe Navyug Co-Operative Vs. Dcit-32(1), Housing Society Ltd., Room.No.702, 7Th Flr, Jaihind Club Bldg, Jvpd Kautilya Bhavan, Scheme, 2Nd Floor, Bandra Kurla N.S. Road,Vile Parle (W), Complex, Mumbai-400049. Bandra(E), Mumbai-400051. Pan/Gir No. : Aaaat0325L Appellant .. Respondent Appellant By : Shri Shalin.S. Divatia.Ar Respondent By : Shri Laxmi Kant.Sr. Dr Date Of Hearing 09.05.2024 Date Of Pronouncement 10.05.2024 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi/Cit (A) Passed U/Sec 154 & U/Sec 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal: The Navyug Co-Op Housing Society Ltd., Mumbai. 1. The Learned Commissioner Of Income Tax (Appeals) Erred In Confirming The Order Of The Assessing Officer Rejecting The Application Of The Assessee U/S 154 Seeking Rectification Of The Disallowance The Deduction U/S 80P(2) & 80P(2)(D) Of The Act Of Rs.60,93,180/- U/S 143 (1) Of The Act.

For Appellant: Shri Shalin.S. Divatia.ARFor Respondent: Shri Laxmi Kant.Sr. DR

Section 143Section 143(1)Section 154Section 80Section 80PSection 80P(2)Section 80P(2)(d)

…ty on its investments held with a cooperative bank would be eligible for claim of deduction under Sec. 80P(2) (d) of the Act. We find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of nonjurisdictional High Court's, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon'ble High Court of jurisdiction, we respectfully follow the view taken by the…

Lake Town Co-Operative Housing Society Limited, Pune vs. Income Tax Officer, Ward-5(2), Pune

Appeal is partly allowed for

ITA 88/PUN/2024[2020-21]Status: DisposedITAT Pune07 May 2024AY 2020-21

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

For Appellant: Shri Hari KrishanFor Respondent: Shri Ramnath P Murkunde

Section 143(3)Section 56Section 80PSection 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “A” BENCH : PUNE [THROUGH VIRTUAL HEARING] BEFORE SHRI RAMA KANTA PANDA, VICE PRESIDENT AND SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER I.T.A.No.88/PUN./2024 Assessment Year 2020-2021 Lake Town Co-operative The Income Tax Officer, Housing Society Limited, vs. Ward-5(2), PMT Bldg., S.No.11, Katraj, PUNE. Swargate, Pune – 411 037. PIN – 411 046. PAN AAAAL3427D Maharashtra. (Appellant) (Respondent) For Assessee : Shri Hari Krishan For Revenue : Shri Ramnath P Murkunde Date of Hearing : 24.04.2024 Date of Pronouncement : 07.05.2024 ORDER PER SATBEER SINGH GODARA, J.M. :…

Income Tax Officer Ward-1, Satara vs. Shree Kalika Devi Nagari Sahakari Pat Sanstha Maryadit Karad, Karad Dist Satara

Appeal is dismissed in above terms

ITA 52/PUN/2024[2020-21]Status: DisposedITAT Pune07 May 2024AY 2020-21

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Ramnath P. Murkunde

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “A” BENCH : PUNE [THROUGH VIRTUAL HEARING] BEFORE SHRI RAMA KANTA PANDA, VICE PRESIDENT AND SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER I.T.A.No.52/PUN./2024 [E-APPEAL] Assessment Year 2020-2021 Shree Kalika Devi Nagari The Income Tax Officer, Sahakari Pat Sanstha Maryadit Ward-1, Manjunath Manor, Karad, 6/1, Kasar Galli, Opposite Y.C. Science vs. Guruwar Peth, KARAD. College, Sadar Bazar, Dist-Satara. PIN – 415 110. SATARA - 415 002. Maharashtra. Maharashtra. PAN AAZAS6081K (Appellant) (Respondent) For Assessee : -None- For Revenue : Shri Ramnath P. Murkunde Date of Heari…

Samarth Nagari Shakari Path Sanstha Maryadit, Parbhani vs. Income Tax Officer, Ward One, Jalna

Appeal is allowed in above terms

ITA 1414/PUN/2023[2020-21]Status: DisposedITAT Pune03 May 2024AY 2020-21

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Manish Mehta

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

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “SMC” BENCH : PUNE BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER I.T.A.No.1414/PUN./2023 [E-APPEAL[ Assessment Year 2020-2021 Samarth Nagari Shakari The Income Tax Officer, Path Sanstha Maryadit, Ward – 1, Wardha Road, PA-1, Nanal Peth, vs. Jalna Industrial Area, MIDC, PARBHANI - 431 401. JALNA. PIN - 431 213. Maharashtra. Maharashtra. PAN AADAS4600A (Appellant) (Respondent) For Assessee : -None- For Revenue : Shri Manish Mehta Date of Hearing : 22.03.2024 Date of Pronouncement : 03.05.2024 ORDER This assessee’s appeal for assessment year 2020-21, arises against the…

Subramanian and Anr. v. Siemens India Ltd. and Anr.

What is Subramanian and Anr. v. Siemens India Ltd. and Anr. authority for?

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Sections most often in play

Issues it is cited on

Judgments citing Subramanian and Anr. v. Siemens India Ltd. and Anr.

Income Tax Officer Ward-2, Ahmednagar vs. Goreshwar Gramin Bigar Sheti Sahakari Pat Sanstha Maryadit, Parner Dist. Ahmednagar

Income Tax Officer, Ward 10(1), Pune, Akurdi vs. Shri Bhairavnat Gramin Bigarsheti Patsanstha Maryadig, Landewadi

Rajat Apartments Co-Op. Housing Society Ltd., Mumbai vs. ACIT Circle 19(3), Mumbai

Rajat Apartments Co.Op. Housing Society, Mumbai vs. ACIT Circle 19(3), Mumbai

Sadhana Sahakari Patpedhi Limited, Vasai, Palghar vs. CIT(A), NFAC, Delhi

Sadhana Sahakari Patpedhi Limited, Palghar vs. CIT(A), NFAC, Delhi

ITO-26(2)(1), Mumbai vs. Sangli Vaibhav Co Operative Credit Society Limited, Mumbai

ITO-26(2)(1), Mumbai vs. Sangli Vaibhav Co Operative Credit Society Limited, Mumbai

ITO-26(2)(1), Mumbai vs. Sangli Vaibhav Co Operative Credit Society Limited, Mumbai

Kundalika Nagari Sahakari Pathsanstha Maryadit, Roha vs. Income Tax Officer, Ward-1, Panvel

Usha Janakalyan Nagar Chs Ltd, Mumbai vs. The Income Tax Officer-30(1)(1), Mumbai

Ganesh Vyapari Gramin Bigarsheti Sahakari Patsanstha Maryadit, Sangli vs. Income Tax Officer, Ward-2, Sangli

Balaji Shrushti Chs Ltd, Panvel vs. ITO, Ward - 1, Panvel

Balaji Shrushti Chs Ltd, New Panvel vs. ITO, Ward - 1, Panvel

Income Tax Officer, Mumbai vs. Larsen Toubro Kamgar Sahakari Patpedni Marydit, Mumbai

Vithal Court Apartments Chs Ltd, Mumbai vs. Assistant Director Income Tax, CPC, Bangaluru, Mumbai

The Navyug Co-Operative Housing Society Ltd., Mumbai vs. DCIT 32(1), Mumbai

Lake Town Co-Operative Housing Society Limited, Pune vs. Income Tax Officer, Ward-5(2), Pune

Income Tax Officer Ward-1, Satara vs. Shree Kalika Devi Nagari Sahakari Pat Sanstha Maryadit Karad, Karad Dist Satara

Samarth Nagari Shakari Path Sanstha Maryadit, Parbhani vs. Income Tax Officer, Ward One, Jalna