THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSHAHR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

c ) (ii), without submitting any details of claim relating to deduction under section 80P(2)(d) of the Act 61, ( as per narration of the AO in para – 5 of the order ) , I.T.A. Nos. 513 to 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 and 2020-21 5 which the Ld AR of the assessee is claiming before

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSAHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

c ) (ii), without submitting any details of claim relating to deduction under section 80P(2)(d) of the Act 61, ( as per narration of the AO in para – 5 of the order ) , I.T.A. Nos. 513 to 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 and 2020-21 5 which the Ld AR of the assessee is claiming before

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSHAHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

c ) (ii), without submitting any details of claim relating to deduction under section 80P(2)(d) of the Act 61, ( as per narration of the AO in para – 5 of the order ) , I.T.A. Nos. 513 to 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 and 2020-21 5 which the Ld AR of the assessee is claiming before

THE DHAMAI COOPERATIVE AGRICULTURE SERVICE SOCIETY LIMITED,HOSHIARPUR vs. INCOME TAX OFFICER WARD, HOSHIARPUR

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.238/Asr/2023 Assessment Year: 2020-21

disallowed the deduction for violation of Section 80P(2)(d) of the the Act. In relation to restriction u/s 80P(4) of the Act. The interest was added back with the total income as income amount of Rs.21,05,192/- as income from other sources. The Revenue authorities had relied on the order of Hon’ble Supreme Court

THE KOT RAM DASS COOP. THIRFT & CREDIT SOCIETY LIMITED,JALANDHAR vs. INCOME TAX OFFICER WARD-2 (4), JALANDHAR

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.86/Asr/2021 Assessment Year: 2017-18

disallowed the deduction for violation of Section 80P(2)(d) of the the Act. In relation to restriction u/s 80P(4) of the Act. The interest was added back with the total income as income amount of Rs.21,05,192/- as income from other sources. The Revenue authorities had relied I.T.A. No.86/Asr/2021 3 Assessment Year: 2017-18 on the order

MALWA CO-OP L & C SOCIETY LTD,MUKTSAR vs. INCOME TAX OFFICER WARD-II(2), MUKTSAR

In the result, the appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

disallowance of deduction u/s 80P(2)(a)(vi) and allowance of deduction u/s 80P(2)(a)(vi). Accordingly, the arguments made by Ld. DR will not help the revenue. Thus, all the grounds of the assessee are allowed for statistical purposes.” During the first assessment the gross receipt of the assessee was determined Rs. 69,02,988/- and the profit

M/S. THE FARIDKOT PRIMARY COOP AGRICULTURAL DEVELOPMENT BANK.LIMITED,FARIDKOT vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3, FEROZEPUR

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

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2)(c) of Income Tax Act may be provided but unfortunately section 80P(4) acts like a weapon cutting across the entire claim of deduction under the main section 80P. There is no confusion on the interpretation that once the appellant falls into the trappings of section 80P(4), it loses complete claim over the deduction is under section

M/S ATHOULA CO-OP AGRICLUTURE MULTIPURPOSE SERVICE SOCIETY LTD,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JALANDHAR

In the result, both the appeal filed by the assessee are dismissed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 80P(2)(a), which is wide enough to include such interest earned by the assessee society in its fold as also affirmed by the Hon'ble Karnataka High Court in the judgement cited supra. 5. The Ld CIT(A) has erred in not allowing to set off, as an alternative the average cost of funds from the said interest

MESRES ATHOULA CO-OP AGRICULTURE MULTIPURPOSE SERVICE SOCIETY LTD,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JALANDHAR

In the result, both the appeal filed by the assessee are dismissed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 80P(2)(a), which is wide enough to include such interest earned by the assessee society in its fold as also affirmed by the Hon'ble Karnataka High Court in the judgement cited supra. 5. The Ld CIT(A) has erred in not allowing to set off, as an alternative the average cost of funds from the said interest

THE HOSHIARPUR CENTRAL COPREATIVE -BANK,HOSHIARPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE HOSHIARPUR, HOSHIARPUR

In the result, ground no. 1 of the assessee has not pressed, ground no-3 is

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

disallowance as made by the AO, the ld. CIT(A) observed that the assessee is not eligible in deduction of the second limb of section 36(1)(viia) of the Act which concerns itself with deduction computed @ 10% of aggregate average advance made rural branches of the assessee. To keeping in view, amended provision to section

THE BAGHAPURANA & CO OPERATIVE MARKETING SOCIETY LTD,MOGA vs. INCOME TAX OFEIER-2, MOGA

In the result, ground nos

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

80P(2) claimed by the assessee treating its income under the head “Business and Profession”. The considering fact, the assessee added back the interest 2,73,342/- on account of income from other sources by invoking section 56 of Act. Interest which was added u/s. 56 was received from Scheduled bank, Axis Bank, Baghapurana and Punjab National Bank

THE HOSHIARPUR CENTRAL COOP. BANK LTD.,HOSHIARPUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, HOSHIARPUR

Bench: Sh. N. K. Choudhry & Sh. O. P. Meena

80P. We decide accordingly.” 6. In view of above, respectively following the decision in assessee’s own case, this ground of Revenue is accordingly dismissed. 7. Ground no. 2 relate to deleting the addition of Rs.6,00,75,946/- made on account of standard loan disallowed by the AO. 8. The Ld. CIT-DR relied on the order

THE ASSTT. COMMISSIONER OF INCOME-TAX, HOSHIARPUR vs. THE HOSIARPUR CENTRAL CO-OPERATIVE BANK LTD., HOSHIARPUR

Bench: Sh. N. K. Choudhry & Sh. O. P. Meena

80P. We decide accordingly.” 6. In view of above, respectively following the decision in assessee’s own case, this ground of Revenue is accordingly dismissed. 7. Ground no. 2 relate to deleting the addition of Rs.6,00,75,946/- made on account of standard loan disallowed by the AO. 8. The Ld. CIT-DR relied on the order

THE DEPUTY COMMISSIONER OF INCOME TAX, HOSHIARPUR vs. HOSHIARPUR CENTRAL COOP. BANK LTD., HOSHIARPUR

Bench: Sh. N. K. Choudhry & Sh. O. P. Meena

80P. We decide accordingly.” 6. In view of above, respectively following the decision in assessee’s own case, this ground of Revenue is accordingly dismissed. 7. Ground no. 2 relate to deleting the addition of Rs.6,00,75,946/- made on account of standard loan disallowed by the AO. 8. The Ld. CIT-DR relied on the order

THE HOSHIARPUR CENTRAL COOP. BANK LTD,HOSHIARPUR vs. THE DY COMMISSIONER OF INCOME TAX, HOSHIARPUR

Bench: Sh. N. K. Choudhry & Sh. O. P. Meena

80P. We decide accordingly.” 6. In view of above, respectively following the decision in assessee’s own case, this ground of Revenue is accordingly dismissed. 7. Ground no. 2 relate to deleting the addition of Rs.6,00,75,946/- made on account of standard loan disallowed by the AO. 8. The Ld. CIT-DR relied on the order