THE ORCHID HEIGHTS CO.OP HOUSING SERVICE SOCIETY LIMITED,AHMEDABAD vs. ITO, WARD-3(3)(5), AHMEDABAD, AHMEDABAD
In the result, the appeal of the assessee is allowed
ITA 26/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Jul 2025AY 2021-22
Bench: Dr. B.R.R. Kumar, Vice- & Ms Suchitra Kamblethe Orchid Heights Co-Op Income Tax Officer, Vs. Housing Service Society Ward-3(3)(5), Limited, Ahmedabad. Applewood Township, Nr. Shantipura Circle, Ahmedabad-382210.. [Pan :Aagat8437 K] (Appellant) .. (Respondent) Appellant By : Shri M J Ranpura, Ar Respondent By: Shri Suresh Chand Meena, Sr. Dr Date Of Hearing 03.07.2025 Date Of Pronouncement 09.07.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:- Delay Condoned This Appeal Is Filed By The Assessee Against The Appellate Order Dated 29.04.2024 Passed By The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, Relating To The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeals:
For Appellant: Shri M J Ranpura, ARFor Respondent: Shri Suresh Chand Meena, Sr. DR
Section 194ASection 194A(3)(v)Section 263Section 80PSection 80P(2)(d)Section 80P(4)
80P(2)(d) is available to the cooperative societies on the income earned as interest on the investment made with the cooperative bank which in turn, is a cooperative society itself. [Para 28]
Reliance placed by the revenue on decisions of the Karnataka High Court in Totgars’ Cooperative Sale Society
(2017) 395 ITR 611 and Supreme Court in case