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interest on securities

Chapter I - PreliminarySection 2 - DefinitionsSection 2(28B) / ITR Schedule OS681 judgments

SHRI BRAHMANATH CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,NIPPANI vs. ITO 1 NIPPANI, NIPPANI

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

ITA 66/PAN/2026[2013-14]Status: DisposedITAT Panaji10 Mar 2026AY 2013-14

Bench: Shri Pavan Kumar Gadalei T A. Nos.66/Pan/2026 (A.Y. 2013-14 ) Shri Brahmanath Credit Vs I.T.O-Ward-1, Souhard Sahakari Sangh Nemchand Building, . Niyamat, 747,Ashoknagar, 185/C, Chikodi Road, Nippani-591237, Nippani, Karnataka. Belagavi-591237, Karnataka. Pan .No. Aaaas1063Q (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.U.G.Ammangi.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.03.2026 घोषणा की तारीख/Date Of Pronouncement 10.03.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Deduction Of Interest Income From Cooperative Society, Cooperative Banks & Nationalized Banks U/Sec80P(2)(D) Of The Act. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Credit Society & Is Engaged In Activities Of Providing Credit Facilities To Its Members. The Assessee Has Filed The Return Of Income For The A.Y 2013-14 On 2 Ita. No..66/Pan/2026 Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit. 30.09.2013 Disclosing A Total Income Of Rs.Nil After Claiming Deduction Of Rs.78,06,780/- U/Sec 80P(2)(A)(I) Of The Act. Subsequently The Case Was Selected For Scrutiny Under Cass & Order U/Sec143(3) Of The Act Was Passed Disallowing The Claim U/Sec80P(2)(A)(I) Of The Act Of Rs.78,06,780/- & Disallowance U/Sec40(A)(Ia) Of The Act Of Rs.76,274/- & Assessed The Total Income Of Rs.78,83,054/- Vide Order Dated21.07.2021.Aggrived By The Order, On Appeal To The Cit(A), The Appeal Was Partly Allowed & The Assessee Has Preferred Second Appeal Before The Honble Tribunal & Vide By Order

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

deduction under section 80P(2)(a)(i) of the Act. The CBDT CIRCULAR No.18/2015 F.No.279/Misc./140/2015/ITJ dated 02.11.2015 on the issue of interest SLR securities of banks states that – 1.“It has been brought to the notice of the Board that in the case of Banks, field officers ... income from other sources." 2. Clause (id) of sub-section (1) of Section 56 of the Act provides that income by way of interest on securities shall be chargeable to income tax under the head "Income from Other Sources", if, the income is not chargeable to income-tax under

SHRI K.P. MAGENNAVAR LAXMI CREDIT SOUHARDA SAHAKARI SANGH LTD.MANJARI.,CHIKODI vs. INCOME TAX OFFICER, WARD-1, NIPPANI

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

ITA 33/PAN/2026[2015-2016]Status: DisposedITAT Panaji27 Feb 2026AY 2015-2016

Bench: Shri Pavan Kumar Gadalei T A. No.33/Pan/2026 (A.Y. 2015-16 ) Shri K.P.Magennavar Laxmi Vs I.T.O-Ward-1, Credit Souharda Sahakari Nemchand Building, . Sangh Limited, 747,Ashoknagar, 521,Laxmibuilding,Mainroad, Nipani-591237, Manjari, Chikodi, Karnataka. Belagavi-591213, Karnataka. Pan .No. Aabas3175N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Jaykumar Patil.Ar Revenue By Smt.Thamba Mahendra.Sr.Dr सुनवाई की तारीख/Date Of Hearing 25.02.2026 घोषणा की तारीख/Date Of Pronouncement 27.02.2026 Order Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of Addl/Jcit(A)-7 Mumbai Passed U/Se 143(3) & U/Sec250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Ac & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act On Interest Income From Cooperative Banks & Scheduled Banks. 2. The Brief Facts Of The Case Are That, The Assessee Souhard Credit Cooperative Society Is Engaged In Providing

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

CBDT CIRCULAR No.18/2015 F.No.279/Misc./140/2015/ITJ dated 02.11.2015 on the 12 ITA. No.33/PAN/2026 Shri.K.P.Magennavar Laxmi Credit Souharda Sahakari Sangh Limited. issue of interest SLR securities of banks states that – 1.“It has been brought to the notice of the Board that in the case of Banks, field officers are taking ... income from other sources." 2. Clause (id) of sub-section (1) of Section 56 of the Act provides that income by way of interest on securities shall be chargeable to income tax under the head "Income from Other Sources", if, the income is not chargeable to income-tax under

INCOME TAX OFFICER, KOLKATA vs. MILESTONE FINSTOCK PVT. LTD., KOLKATA

In the result, the appeal filed by the revenue is dismissed

ITA 1180/KOL/2023[2012-13]Status: DisposedITAT Kolkata24 Feb 2026AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Ito, Ward-12(1), Kolkata…..…………..………….……….……….……Appellant Vs. Milestone Finstock Pvt. Ltd..……...…………………….....……...…..…..Respondent 62A, Hazra Road, Kol-700019. [Pan: Aaccm0280B] Appearances By: Shri Mohit Mrinal, Cit-Dr, Appeared On Behalf Of The Appellant. Shri N S Saini, Ar & Priyanka Salarpuria, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 07, 2026 Date Of Pronouncing The Order : February 24, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 24.09.2020 Of The Cit(Appeals)-4, Kolkata (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2012–13. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 1075 Days & The Revenue Has Filed An Affidavit For Condonation Of The Delay. The Contents Of The Said Affidavit Are As Under: Milestone Finstock Pvt. Ltd

Section 143(2)Section 143(3)Section 250Section 73

business of a company [other than a company whose gross total income consists mainly of income which is chargeable under the heads “Interest on securities”, “Income from house property”, “Capital gains” and “Income from other sources”], or a company the principal business of which is the business of banking

CHHATTISGARH HOUSING BOARD,RAIPUR vs. EXEMPTION CIRCLE, RAIPUR

In the result, this appeal of the assessee is allowed as above for statistical purposes

ITA 653/RPR/2025[2017-18]Status: DisposedITAT Raipur17 Feb 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR
Section 11Section 12ASection 250

banking company during one day amounting to Rs. 2,94,49,120/- and received contract receipts of Rs. 39,24,946/- and received interest on securities of Rs. 21,551/-. Since no return of income was filed by the appellant, the receipts of F.Y. 2010-11 remained unoffered ... received Chhattisgarh Housing Board vs. ACIT (E), Raipur contract receipts of Rs. 39,24,946/- and was in receipt of interest on securities of Rs. 21,551/- however did not file the return of income. Therefore, receipts of Rs. 3,33,95,617/- remained unoffered for the purpose of taxation

CHHATTISGARH HOUSING BOARD,RAIPUR vs. EXEMPTION CIRCLE, RAIPUR

In the result, this appeal of the assessee is allowed as above for statistical purposes

ITA 652/RPR/2025[2016-17]Status: DisposedITAT Raipur17 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR
Section 11Section 12ASection 250

banking company during one day amounting to Rs. 2,94,49,120/- and received contract receipts of Rs. 39,24,946/- and received interest on securities of Rs. 21,551/-. Since no return of income was filed by the appellant, the receipts of F.Y. 2010-11 remained unoffered ... received Chhattisgarh Housing Board vs. ACIT (E), Raipur contract receipts of Rs. 39,24,946/- and was in receipt of interest on securities of Rs. 21,551/- however did not file the return of income. Therefore, receipts of Rs. 3,33,95,617/- remained unoffered for the purpose of taxation

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