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:

4. Dividend from Other Co-op Society (ADC Rs. 1,50,015/- Rs. 1,50,015/- Bank) 5. Members Interest on FD Rs. 1,07,060/- Rs. 68,395/- Allowable Exemption u/s 80P(2)(a)(i) Interest on Interest on Members Members Loan Rs. Loan Rs. 82,29,369/- 74,71,157/- 3. The assessee preferred and appeal before

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:

4. Dividend from Other Co-op Society (ADC Rs. 1,50,015/- Rs. 1,50,015/- Bank) 5. Members Interest on FD Rs. 1,07,060/- Rs. 68,395/- Allowable Exemption u/s 80P(2)(a)(i) Interest on Interest on Members Members Loan Rs. Loan Rs. 82,29,369/- 74,71,157/- 3. The assessee preferred and appeal before

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

4– claimed as a deduction under Section 80P of the Income Tax Act. The Assessee's income from processing cotton bales amounted to Rs. 53,53,310/-, which qualified for the same deduction. The Assessee submitted that there was no error in the assessment and that any jurisdiction under section 263 must be based on the order being

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

4) of the Act. It was only subsequently through a letter dated 22.11.2019 that a return of income was filed claiming deduction under section 80P of the Act amounting to Rs.17,97,494/- . The same was denied by the Assessing Officer invoking section 80A(5) of the Act , which requires such claims to be made in the returns

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

80P(2)(a)(i) be deleted. 2. The Commissioner of Income Tax (Appeals) erred on facts without appreciating the circumstances of the case and in Law in holding that cash deposits of Rs.1,15,97,500/- in the bank account during demonetization period as unexplained cash credit u/s. 68 is wholly illegal, unlawful and against the principles of natural justice

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:

4. Aggrieved by the said assessment order, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals). The assessee raised multiple grounds, inter alia, challenging the validity of reopening under section 148 of the Act, the addition made under section 68, and the disallowance of deduction under section 80P

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 of the Act amounting to " 29, 05, 816/-. The assessee submitted that assessee had earned an interest of INR 4,68

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 income and fixed deposit interest are required to be disallowed and, therefore, proceedings under Section 147 of the Act was initiated and notice under Section 148 of the Act was issued to the assessee. In response

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 income and fixed deposit interest are required to be disallowed and, therefore, proceedings under Section 147 of the Act was initiated and notice under Section 148 of the Act was issued to the assessee. In response

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

4 of 6 issue of allowing pro rata expenses and allowing statutory deduction of Rs.50,000/- u/s 80P(2)©(ii) of the Act has been adjudicated by the Co- ordinate Bench by observing as under :- 10. From going through the alternate submissions made by the assessee we find that major portion of interest income is from government securities

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 and circumstances of the case, the Ld. Commissioner of Income- Tax (Appeals) ought to have upheld the order of the Assessing Officer. (iii) It is, therefore prayed that the order of the Ld. Commissioner of Income-tax(Appeals

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

MUNCIPAL SERVANT CO. OP CREDIT AND SUPPLY SOC. LTD,AHMEDABAD vs. THE DCIT, CPC , BENGLURU

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

68 taxmann.com 298 (Kerala), the Kerala High Court held that a return filed by assessee beyond period stipulated under section 139(1) or 139(4) or under section 142(1) or section 148 can also be accepted and acted upon for entertaining claim raised under section 80P

MUNCIPAL SERVANT CO. OP CREDIT AND SUPPLY SOC. LTD,AHMEDABAD vs. THE DCIT, CPC , BENGLURU

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

68 taxmann.com 298 (Kerala), the Kerala High Court held that a return filed by assessee beyond period stipulated under section 139(1) or 139(4) or under section 142(1) or section 148 can also be accepted and acted upon for entertaining claim raised under section 80P

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

4 Different assessees vs. ITO facilities to its members and the interest income earned on fixed deposit from Bank of Baroda and MGVCL cannot be termed as activity of providing credit facilities to its members therefore, such interest income would not qualify for deduction u/s 80P(2)(a)(i) of the act. Therefore, deduction of Rs. 10,64,670/- pertaining

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

4 Different assessees vs. ITO facilities to its members and the interest income earned on fixed deposit from Bank of Baroda and MGVCL cannot be termed as activity of providing credit facilities to its members therefore, such interest income would not qualify for deduction u/s 80P(2)(a)(i) of the act. Therefore, deduction of Rs. 10,64,670/- pertaining

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

4 Different assessees vs. ITO facilities to its members and the interest income earned on fixed deposit from Bank of Baroda and MGVCL cannot be termed as activity of providing credit facilities to its members therefore, such interest income would not qualify for deduction u/s 80P(2)(a)(i) of the act. Therefore, deduction of Rs. 10,64,670/- pertaining

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

4 Shree Vaishnav Parivar Sahakari Mandali Ltd. vs. ITO also submitted that a total expenses incurred for the year stood at Rs.28,60,298/- and pro rata expenses for earning interest income of Rs.8,55,854/- as against total interest income of Rs.42,39,515/- will be calculated at Rs.5,77,423/-. 11. We observe that Id. AR has referred

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

68 for unexplained cash credits, disallowance of deduction under section 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