UNION BANK CO. OP. CREDIT SOCIETY LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1228 & 1229/Ahd/2024 िनधा"रण वष" /Assessment Years: 2018-19 & 2020-21 Respectively Union Bank Co-Op. Credit The Dy.Cit बनाम/ Society Ltd. Circle-1(1)(1) V/S. 1, Dhalaxmi Market Ahmedabad Revadi Bazar Kalupur Ahmedabad – 380 001 (Gujarat) "थायी लेखा सं./Pan:Aaau 0802 F (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Anil Kshatriya, Advocate Revenue By : Smt. Bhavna Gupta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 24/09/2024 घोषणा की तारीख /Date Of Pronouncement: 08/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

d) of the Act, adding back interest income of Rs.14,62,802 for A.Y. 2018-19 and Rs.10,69,772 for A.Y. 2020-21. The AO’s decision was primarily based on the interpretation that the interest income from deposits with nationalized and co-operative banks does not constitute operational income eligible for deductions under section 80P. Details

ITO MEHSANA WARD 5 KADI, KADI vs. THE GOZARIA PEOPLES CO OPERATIVE CREDIT SOCIETY LIMITED, GOZARIA

Appeal is dismissed

Bench: Dr. Brr Kumar & Shri T.R. Senthil Kumari.Ta. No.1819/Ahd/2024 (Assessment Year: 2018-19) The Income Tax Officer, Vs. The Gozaria Peoples Co- Mehsana Ward 5, Operative Credit Society Kadi. Limited, Gozaria 2, Main Bazar At Gozaria Ta. Mehsana Dist. Mehsana-383825 [Pan No.Aaajt1283G] (Appellant) .. (Respondent) Appellant By : Shri B K Patel, Ar Respondent By: Smt. Trupti Patel, Sr. Dr

80P(2)(d) which is in consonance with the various decisions of the Court as a twin condition invoking section 263 as to the assessment being erroneous and prejudicial to the interest of the revenue are not being fulfilled. [Para 33]  In view of the foregoing reasons the question is answered in favour of the assessee and against

ITO, WARD-5(3)(1), VEJALPUR vs. AHMEDABAD DISTRICT CO OP MILK PRODUCERS UNION LTD, AHMEDABAD

In the result, both the appeals filed by the Revenue are dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokar

68,870/- and interest income of Rs.1,35,06,370/-. But as per Section 80P(2)(d) of the Act, dividend

THE ITO, WARD-5(3)(1), AHMEDABAD vs. AHMEDABAD DISTRICT CO.OP.MILK PRODUCERS UNION LTD., AHMEDABAD

In the result, both the appeals filed by the Revenue are dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokar

68,870/- and interest income of Rs.1,35,06,370/-. But as per Section 80P(2)(d) of the Act, dividend

THE SANKHEDA JETPUR PAVI TALUKA GINNING PRESSING COTTON SALE CO.OP SOCIETY LTD,VADODARA vs. THE PR. CIT-3, VADODARA

In the result, the appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

D E R PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This appeal has been filed by the Assessee against the order passed by the Ld. Principal Commissioner of Income Tax-3, (in short “Ld. PCIT”), Vadodara, vide order dated 16.03.2020 passed for A.Y. 2015-16. 2. The Assessee has taken the following grounds of appeal:- “Invalid Revision u/s 263: 1. The learned

SHRI FRIENDS CO. OP. CREDIT SOCIETY LIMITED,,VADODARA vs. THE INCOME TAX OFFICER, WARD-3(1)(2),, VADODARA

The appeal of the assessee is partly allowed for statistical purposes

d).In view of decision of Hon'ble High Court of Gujarat as supra we considered that the AO has correctly made disallowance of claim of deduction of Rs. 10,64,672/- u/s 80P of the IT Act by treating the same as income from other sources on the ground that this amount of interest income as earned on deposits

I.M.A. VADODARA CO.-OP. CREDIT SOC. LTD.,,VADODARA vs. THE INCOME TAX OFFICER, WARD-3(1)(2),, VADODARA

The appeal of the assessee is partly allowed for statistical purposes

d).In view of decision of Hon'ble High Court of Gujarat as supra we considered that the AO has correctly made disallowance of claim of deduction of Rs. 10,64,672/- u/s 80P of the IT Act by treating the same as income from other sources on the ground that this amount of interest income as earned on deposits

SHRI SAHAJANAND CO. OP. CREDIT SOCIETY LTD.,,VADODARA vs. THE INCOME TAX OFFICER, WARD-3(1)(2),, VADODARA

The appeal of the assessee is partly allowed for statistical purposes

d).In view of decision of Hon'ble High Court of Gujarat as supra we considered that the AO has correctly made disallowance of claim of deduction of Rs. 10,64,672/- u/s 80P of the IT Act by treating the same as income from other sources on the ground that this amount of interest income as earned on deposits

THE ACIT, PATAN CIRCLE, PATAN vs. THE SARDAR PATEL CO OPERTAIVE CREDIT SOCIETY LIMITED, MEHSANA

In the result, the appeal of the revenue is dismissed

68,200/- on account of interest earned under section 80P(2)(d) of the Act. (ii) On the facts

SHRE VAISHNAV PARIVAR SAHAKARI MANDALI LTD.,,VADODARA vs. THE INCOME TAX OFFICER, WARD-3(1)(1),, VADODARA

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

d). 5.2 In view of decision of Hon'ble High Court of Gujarat as given in the case of State Bank of India vs. Commissioner of Income Tax, 72 Taxmann.com 64, it is held that the AO has correctly made disallowance of claim of deduction of Rs.1,62,993/- of the appellant as made u/s 80P(2

THE MEHLAV PEOPLES CO-OP. CREDIT SOCIETY LTD.,PETLAD vs. THE DCIT, CIRCLE-1(3),, VADODARA

In the result, the appeal is partly allowed in the terms indicated above

Bench: Shri Pramod Kumar] Assessment Year : 2012-13 The Mehlav Peoples Co-Op. Credit Society Ltd ......…………......Appellant Opp. Goverdhannath Temple, Mehlav, Tal. Petlad – 388 440 [Pan – Aaaat 2312 D] Vs. The Dy. Commissioner Of Income-Tax .......................Respondent Circle-1(3), Vadodara

D E R 1. By way of this appeal, the assessee appellant has challenged correctness of learned CIT(A)’s order dated 27th June 2017 in the matter of assessment under section 143(3) of the Income-tax Act, 1961 for the assessment year 2012-13. 2. Grievances raised by the appellant are as follows:- “1. The learned

SHRI MAHILA CO. OP. CREDIT SOCIETY LTD.,BOTAD vs. THE ACIT, CIRCLE-1, BHAVNAGAR

In the result, the appeal of the assessee is allowed

section 80P(2)(d) of the Act. Accordingly, the AO disallowed deduction on interest of " 4,68,333/-earned

APOLLO TYRES EMPLOYEES MULTIPUROPSE CONSUMER CO. OPERATIVE CREDIT SOCIETY LTD.,,VADODARA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-3(1),, BARODA

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

d). 5.2 In view of decision of Hon'ble High Court of Gujarat as given in the case of State Bank of India vs. Commissioner of Income Tax, 72 Taxmann.com 64, it is held that the AO has correctly made disallowance of claim of deduction of Rs.21,72,701/- of the appellant as made u/s 80P by treating the same

SHRI VIR TRANSPORT OPERTORS COPO CREDIT & SERVICE SOCIETY LTD.,DAHOD vs. THE DY. CIT, ANAND CIRCLE, AHMEDABAD

In the result, the appeal of the assessee is partly allowed

80P(2)(a)(i) and section\n80P(2)(d) and for computing income taxable under the head income\nfrom other sources under section 56.\n12. It was argued that the above computation was filed before the\nAssessing Officer as well as the CIT(A), supported by audited accounts,\nand demonstrates that the expenditure was incurred wholly and\nexclusively

SHRI LAXMI CO. OP. CREDIT SOCIETY LTD. vs. THE INCOME TAX OFFICER, WARD-3(1)(2),, BARODA

In the result, the appeal is allowed for statistical purposes

Bench: Shri Pramod Kumar] Assessment Year: 2013-14

d).In view of decision of Hon'ble High Court of Gujarat as supra we considered that the AO has correctly made disallowance of claim of deduction of Rs. 10,64,672/- u/s 80P of the IT Act by treating the same as income from other sources on the ground that this amount of interest income as earned on deposits

THE POSUN CO. OP. CREDIT SOCIETY LTD.,,BARODA vs. THE INCOME TAX OFFICER, WARD-3(1)(5),, BARODA

In the result, the appeal is allowed for statistical purposes

Bench: Shri Pramod Kumar] Assessment Year: 2013-14

d).In view of decision of Hon'ble High Court of Gujarat as supra we considered that the AO has correctly made disallowance of claim of deduction of Rs. 10,64,672/- u/s 80P of the IT Act by treating the same as income from other sources on the ground that this amount of interest income as earned on deposits

SAVLI TALUKA SECONDARY AND HIGHER SECONDARY EMPLOYEES CO OP. CREDIT SOCIETY LIMITED,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(2), VADODARA

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1772/Ahd/2024 िनधा"रण वष" /Assessment Year : 2019-20 Savli Taluka Secondary & The Income Tax Officer बनाम/ Higher Secondary Employees Ward-1(2)(2) V/S. Co-Op. Credit Society Ltd. Vadodara – 390 007 18, Rayakaka Park Savli Desar Road Vadodara – 391 770. "थायी लेखा सं./Pan: Aafas 6647 D (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Sanket Bakshi, Ar Revenue By : Shri Abhijit Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/08/2025 घोषणा की तारीख /Date Of Pronouncement: 04/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

80P(2)(a)(i) of the Act. Other Grounds Savli Taluka Secondary and Higher Secondary Employees Co-op. Credit Society Ltd. vs. ITO Asst. Year : 2019-20 9. The learned CIT(A) and the learned AO erred in fact and in law in charging interest u/s. 234A of the Act. 10. The learned CIT(A) and the learned AO erred

SHRI UMIYA COOPERATIVE CREDIT SOCIETY LTD. ,1, SENETARY ROAD , KUTCHHI PATIDAR VADI, PETLAD TAL. PETLAD DIST. ANAND vs. INCOME TAX OFFICER, WARD-1(3)(1), PETLAD

In the result, Ground No. 2 of the assessee’s appeal is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

D E R PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated 27.05.2022 for Assessment Year 2017-18. 2. The Assessee has taken the following grounds of appeal

ITO MEHSANA WARD 5 KADI, KADI vs. THE GOZARIA PEOPLES CO OPERATIVE CREDIT SOCIETY LIMITED, GOZARIA

The appeal stands dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21 Ito, Mehsana Ward-5 The Gozaria Peoples Co-Operative Kadi. Vs Credit Society Ltd. 2, Main Bazar At Gozariya Ta. Mehsana 383 825 Gujarat. Pan : Aaajt 1283 G (Applicant) (Responent) : Shri B.K. Patel, Ar Assessee By Revenue By : Shri Durga Dutt, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 02/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 22/05/2025 आदेश आदेश/O R D E R आदेश आदेश

section 80P(2)(d). 4. Aggrieved by the order of CIT(A), the Revenue is in appeal before us raising following grounds of appeal: a) The Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs.15,14,46,954/- made u/s 68