THE VISNAGAR NAGRIK SAHAKARI BANK LTD.,MEHSANA vs. THE ACIT, CIRCLE-GANDHINAGAR (PREVIOUSLY DCIT, PATAN CIRCLE, PATAN), GANDHINAGAR

In the result, the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.738, 1414 & 1415/Ahd/2025 िनधा"रण वष" /Assessment Years : (2013-14, 2014-15 & 2015-16) The Visnagar Nagarik Sahakari The Assistant Commissioner Bank Ltd.,(Under Liquidation) बनाम Of Income Tax, / Market Yard, Circle Gandhinagar. V/S. Visnagar, (Previously Dcit, Mehsana-384315, Patan Circle, Patan) "थायी लेखा सं./Pan: Aaaft8764C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A P Nanavaty, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] These Three Appeals By The Assessee Are Directed Against The Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “The Cit(A)”], All Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Arising From The Assessments Framed By The Assistant / Deputy Commissioner Of Income-Tax, Circle, Patan [Hereinafter Referred To As “The Assessing Officer Or Ao”] Under Section 143(3) Of The Act.

condonation of delay however also examined the matter on merit and dismissed the appeal. For other two assessment years also the CIT(A) dismissed the appeal of the assessee on merit. The assessee raised multiple grounds before CIT(A). In the first ground, it was contended that the AO had erred in disallowing deduction under section 80P

THE VISNAGAR NAGRIK SAHAKARI BANK LTD (UNDER LIQUIDATION),MEHSANA vs. THE ACIT, CIRCLE-GANDHINAGAR (PREVIOUSLY DCIT, PATAN CIRCLE, PATAN), GANDHINAGAR

In the result, the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.738, 1414 & 1415/Ahd/2025 िनधा"रण वष" /Assessment Years : (2013-14, 2014-15 & 2015-16) The Visnagar Nagarik Sahakari The Assistant Commissioner Bank Ltd.,(Under Liquidation) बनाम Of Income Tax, / Market Yard, Circle Gandhinagar. V/S. Visnagar, (Previously Dcit, Mehsana-384315, Patan Circle, Patan) "थायी लेखा सं./Pan: Aaaft8764C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A P Nanavaty, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] These Three Appeals By The Assessee Are Directed Against The Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “The Cit(A)”], All Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Arising From The Assessments Framed By The Assistant / Deputy Commissioner Of Income-Tax, Circle, Patan [Hereinafter Referred To As “The Assessing Officer Or Ao”] Under Section 143(3) Of The Act.

condonation of delay however also examined the matter on merit and dismissed the appeal. For other two assessment years also the CIT(A) dismissed the appeal of the assessee on merit. The assessee raised multiple grounds before CIT(A). In the first ground, it was contended that the AO had erred in disallowing deduction under section 80P

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

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:

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: 1. The ground of appeal mentioned hereunder are without prejudice to one another

VIJAY CREDIT AND SUPPLY CO. OP. SOCIETY,DHOLKA vs. THE PR. CIT-3, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

condone the delay in filing the appeal by the assessee. 6. The brief facts of the case are that the assessee had filed return of income for A.Y. 2016-17 declaring total income at Rs. NIL and had claimed deduction under Section 80P

THE MODASA DHANSURA TALUKA TEACHERS CO.OP. CREDIT SOCIETY LTD.,ARVALLI vs. THE ACIT, HMT CIRCLE, HIMATNAGAR PRESENT JURISDICTION THE DY.CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1478/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 The Modasa Dhansura Taluka The Acit बनाम/ Teachers Co-Op.Credit Hmt Circle, Himatnagar V/S. Society Ltd. Present Jurisdiction - S/43, 2Nd Floor The Dy.Cit, Circle-2(1)(1) Shyam Sunder Complex Ahmedabad – 380 015 Station Road, At & Po Modasa Ta. Modasa Aravalli 383 315 (Gujarat) "थायी लेखा सं./Pan:Aabat 2852 M अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri V.K. Mangla, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/10/2024 घोषणा की तारीख /Date Of Pronouncement: 28/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

delay in filing the appeal before the Addl.CIT(A) was due to sufficient cause and is accordingly condoned. Now we decide the issue on merits. 8.1. Considering that the issue involves the disallowance of Section 80P

RANDHEJA DUDH UTPADAK SAHAKARI MANDLI LTD.,GANDHINAGAR vs. THE ITO, WARD-3 NOW WARD-1, GANDHINAGAR

The appeal of the assessee is allowed

Bench: Smt.Annapurna Guptaasstt. Year : 2017-18 Randheja Dudh Utpadak The Ito, Ward-3 Sahakari Mandli Ltd. Vs Now Ward-1 To-Randheja Gandhinagar. Tal: Gandhinagar Pin : 382 620 Pan : Aacar 5164 K (Applicant) (Responent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri Ketan Gajjar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 27/06/2024 आदेश/O R D E R आदेश आदेश आदेश The Present Appeal Has Been Filed By The Assessee Against Order Passed By The Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre, Delhi [In Short Referred To As Ld.Cit(A)] Under Section 250 Of The Income Tax Act, 1961 Dated 22.11.2021 Pertaining To Asst.Year 2017-18. 2. The Registry Has Notified That The Appeal Of The Assessee Is Barred By Limitation By 581 Days. In Order To Explain The Reasons For The Impugned Delay, The Ld.Counsel For The Assessee Submitted That The Cit(A)/Nfac Order Was Passed Against The Assessee On 22.11.2021. However, Due To Covid-19 Pandemic Limitation For Filing Appeal Before The Court Of Law Was Extended Till February, 2022. Therefore, After Expiry Of The Limitation For Filing Of The Appeal On Feb., 2022, The Assessee Was Required To File Appeal Within 60 Days Of The Same I.E. By April, 2022. But The Assessee Could File The Appeal On

section 250 of the Income Tax Act, 1961 dated 22.11.2021 pertaining to Asst.Year 2017-18. 2. The Registry has notified that the appeal of the assessee is barred by limitation by 581 days. In order to explain the reasons for the impugned delay, the ld.counsel for the assessee submitted that the CIT(A)/NFAC order was passed against the assessee

THE SALESTAX EMPLOYEES CO.OP. CREDIT SOCIETY LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(3), AHMEDABAD

In the result, appeal of the assessee in ITA no

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad , Which Has Arisen From The Appellate Order Dated 16-10-2023 In Din

condone the delay of 111 days and proceed to adjudicate this appeal on merits in accordance with I.T.A No. 612/Ahd/2024 A.Y. 2017-18 Page No. 5 The Sales Tax Employees Co.Op. Credit Society ltd. v. ACIT law. Reference is drawn to the decision of Hon’ble Supreme Collector of Land Acquisition, Court in the case of Anantnag v. Mst. Katiji

NADIAD TALUKA PRATHMIK SHIKSHAKONI DHIRAN & GRAHAK SAHAKARI MANDALI LIMITED,NADIAD vs. THE PCIT-1, VADODARA

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

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2017-18

80P(2)(d) of the Act. The PCIT issued show cause notice dated 14.03.2022 for Assessment Year: 2017-18 Page 3 of 6 proposed revision of the Assessment Order under Section 263 of the Act. As the assessee has not filed any response, the PCIT held that the Assessment Order passed under Section 143(3) of the Act dated

KHERALU TALUKA PRIMARY TEACHERS CO. OP. CREDIT SOCIETY NIYAMIT,MEHSANA vs. NFAC, DELHI PRESENT JURISDICTION -THE ITO, WARD-1, PATAN

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

condone the present delay in the interests of justice 4. The brief facts of the case are that the assessee is a credit co- operative society engaged in providing credit facilities to its members. The assessee filed its original return of income declaring “Nil” income after claiming deduction of ₹36,99,361/- under section 80P

SINHUJ DUDH UTPADAK SAH MAN LIMITED,KHEDA vs. THE ITO, WARD-1, NADIAD

The appeal of the assesse is allowed for statistical purposes

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 80P of the Act, it was only the profit element embedded in the receipt of the assessee, that was liable to tax. He contended that on account of non- condonation of the delay

THE ANKLAV MERCANTILE CO-OP CREDIT SOCIETY LTD.,ANAND vs. DCIT CIRCLE 1(1)(1), VADODARA, VADODARA

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

80P, interest income taxed under the head "income from other sources", and additions under section 69 for unexplained investments. In such circumstances, denying the assessee an opportunity to contest the additions on merits merely on the ground of delay, when a reasonable cause is explained, would be an act of substantial injustice. The principles of natural justice demand that

VIKAS CO. OP CREDIT SOC. LTD,MEHSANA vs. ITO, WARD-3, MEHSANA

In the result, the appeal of the assessee is allowed

condoning the delay in filing the appeal. 5.1 On merits, the issue for consideration before us is whether the assessee is eligible to claim deduction on interest earned from Co-Operative Banks u/s 80P(2)(d) of the Act. In our considered view, Ld. CIT(A) has erred in law in holding that the observations of the Hon’ble Gujarat

THE KHEDBRAHMA TALUKA PRIMARY TEACHERS CO.OP. CREDIT SOCIETY LTD.,HIMATNAGAR vs. THE INCOME TAX OFFICER, WARD-1, HIMATNAGAR

In the result, appeal of the assessee in ITA no

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad , Which

condone the delay of 9 days and proceed to adjudicate this appeal on merits in accordance with law. Reference is drawn to the decision of Hon’ble Supreme Court in the case of Collector of Land Acquisition, Anantnag v. Mst. Katiji (1987 AIR 1353(SC)). 3. The grounds of appeal raised by the assessee in Memo of Appeal filed with

GUJARAT FISHERIES CENTRE CO .OPERATIVE ASSOCIATION LIMITED,,AHMEDABDA vs. ITO, WRAD-5(2)(2),, AHMEDABAD

In the result, the appeal of the assessee is dismissed

condoning the delay in filing the appeal of the assessee. 4. On merits, the facts of the case are that the assessee is a cooperative Society deriving income from trading in diesel, oil kerosene, etc. The Principal Commissioner of Income Tax observed that on perusal of the assessment order, it can be seen that the assessing officer had not properly

SHRI MODHESHWARI BACHAT DHIRAN ANE GRAHAK SAHAKARI MANDALI LTD.,BANASKANTHA vs. THE ITO, WARD-1(PREVIOUSLY WARD-5), PALANPUR

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

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

condonation of delay which is illegal and bad-in-law. I.T.A No. 1977/Ahd/2024 A.Y. 2012-13 Page No 3 Shri Modheshwari Bachat Dhiran Ane Grahak Sakhakri Mandli Ltd. Vs. ITO [3] The appellant therefore requests your Honour to kindly delete the addition of Rs. 3,88,405/- being the interest amount received from the co.op. bank made

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), AHMEDABAD, AAYKAR BHAWAN VEJALPUR vs. SABARKANTHA DISTRICT CO-OPERATIVE MILK PRODUCERS UNION LIMITED, MILK PRODUCERS UNION LIMITED

Appeal is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condoned on due consideration of facts and owing to smallness of delay causing no perceptible prejudice to other side. 3. The Department has raised the following grounds of appeal are as under: “ITA No. 1588/Ahd/2024 (A.Y. 2016-17) 1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1) AHMEDABAD, AAYKAR BHAWAN VEJALPUR, PRAHLAD NAGAR vs. SABARKANTHA DISTRICT CO-OPERATIVE MILK PORODUCERS UNION LIMITED, MILK PRODUCERS UNION

Appeal is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condoned on due consideration of facts and owing to smallness of delay causing no perceptible prejudice to other side. 3. The Department has raised the following grounds of appeal are as under: “ITA No. 1588/Ahd/2024 (A.Y. 2016-17) 1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified

MALPUR TALUKA PRIMARY TEACHERS SAHKARI SAKH & GRAHAK SAHKARI MANDLI,MALPUR vs. THE ACIT., HIMATNAGAR CIRCLE, HIMATNAGAR

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Smt.Annapurna Guptaasstt.Year : 2018-19 Malpur Taluka Primary Acit, Himatnagar Circle Teachers Sahkari Sakh & Vs Himatnagar. Grahak Sahkari Mandali, Malpur, Dist. Aralli Malpur 383 345. Pan : Aacat 9023 F (Applicant) (Responent) : Shri S.N. Divatia, Ar Assessee By : Shri N.J. Vyas, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 09/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 24/04/2024 आदेश आदेश/O R D E R आदेश आदेश

section 80P(2)(d) amounting to Rs.39,80,161/- in respect of interest income from the cooperative. The assessee's appeal before the first appellate authority was outrightly rejected on the grounds that ITA No.821 /Ahd/2023 2 the assessee had delayed filing its appeal before the learned CIT(A) by 246 days. 3. Before me, the ld.counsel for the assessee