M/S. AMPAR CO-OPERATIVE AGRICULTURE SOCIETY LIMITED,UDUPI vs. INCOME-TAX OFFICER, WARD-1, UDUPI

In the result, the appeals of the Assessee for AY 2013-14 & 2014-15 are allowed while the appeal for AY 2015-16 is partly allowed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

TDS under law, such disallowance would ultimately increase assessee’s profits from business of developing housing project. The ultimate profits of assessee after adjusting disallowance under section 40[a][ia] of the Act would qualify for deduction under section 80IB of the Act. This view was taken by the courts in the following cases: [a] Income-tax Officer-Ward

M/S. AMPAR CO-OPERATIVE AGRICULTURE SOCIETY LIMITED,UDUPI vs. INCOME-TAX OFFICER, WARD-1, UDUPI

In the result, the appeals of the Assessee for AY 2013-14 & 2014-15 are allowed while the appeal for AY 2015-16 is partly allowed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

TDS under law, such disallowance would ultimately increase assessee’s profits from business of developing housing project. The ultimate profits of assessee after adjusting disallowance under section 40[a][ia] of the Act would qualify for deduction under section 80IB of the Act. This view was taken by the courts in the following cases: [a] Income-tax Officer-Ward

ITO, SIRSI vs. THE TOTAGARS CO-OPERATIVE SALE SOCIETY, SIRSI

In the result, the appeals of the revenue as well as the cross objections of the assessee are dismissed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

E R Per BENCH: These six appeals by the revenue and four cross objections by assessee are directed against the respective orders of the CIT(A) for the assessment years 2007-08 to 2012-13. ITA Nos.704 to 709 & CO Nos.179 to 182/Bang/2015 Page 2 of 12 2. The revenue has raised common issues/grounds in these six appeals. The grounds

SHARAVATHI PATHINA SAHAKARI SANGHA NIYAMITHA,SHIVAMOGGA vs. INCOME TAX OFFICER,WARD-5, BANGALORE

In the result, the appeals of the Assessee for AY 2013-14 &

Bench: Shri N. V. Vasudevan

E R These are three appeals by the Assessee against three orders all dt. 15.3.2019 of CIT(A), Davangere, relating to Assessment Years 2013-14 to 2015-16. There are common issues involved in these appeals and were therefore heard together. 2. The common issue that arises for consideration in the appeal is as to whether the Revenue authorities were

SHARAVATHI PATHINA SAHAKARA SANGHA NIYAMITHA,SHIVAMOGGA vs. INCOME TAX OFFICER, WARD-5, BANGALORE

In the result, the appeals of the Assessee for AY 2013-14 &

Bench: Shri N. V. Vasudevan

E R These are three appeals by the Assessee against three orders all dt. 15.3.2019 of CIT(A), Davangere, relating to Assessment Years 2013-14 to 2015-16. There are common issues involved in these appeals and were therefore heard together. 2. The common issue that arises for consideration in the appeal is as to whether the Revenue authorities were

SHARAVATHI PATHINA SAHAKARA SANGHA NIYAMITHA,SHIVAMOGGA vs. INCOME TAX OFFICER, WARD-5, BANGALORE

In the result, the appeals of the Assessee for AY 2013-14 &

Bench: Shri N. V. Vasudevan

E R These are three appeals by the Assessee against three orders all dt. 15.3.2019 of CIT(A), Davangere, relating to Assessment Years 2013-14 to 2015-16. There are common issues involved in these appeals and were therefore heard together. 2. The common issue that arises for consideration in the appeal is as to whether the Revenue authorities were

SHREE BASAVESHWAR CREDIT CO-OP SOCIETY LIMITED,HUNGUND vs. INCOME-TAX OFFICER, WARD-1, BAGALKOT

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

E R Per Laxmi Prasad Sahu, Accountant Member : This is an appeal filed by the assessee against the order passed by the CIT(A), Hubballi dated 29.03.2019, with the following grounds of appeal : The order of the learned Commissioner of Income Tax (Appeals) in 1. so far as it is against the appellant is opposed to law, equity and weight

INCOME TAX OFFICER WARD-1, BAGALKOT vs. SHRI BAPOOJI PATTIN SOUHARD SAHAKARI NIYAMIT , BAGALKOT

Bench: Shri Inturi Rama Rao & Shri Laliet Kumarassessment Year : 2013-14

TDS provisions are not applicable. 5. The revenue is in appeal before us contesting only against the finding of the CIT(Appeals) allowing the benefit u/s. 80P of the I.T. Act. The ld. Sr.DR vehemently contended that the respondent-assessee co- operative society is not eligible for deduction for the benefit of section 80P as it is engaged

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

80P. The Apex court had categorically held that investments made by a banking concern are part of the business of banking. In the present case also the investments held by banks are treated only as part of the business of banking only but not as a Stock in Trade but as a Capital Asset. 8.4 Further, both the parties also

SRI SRI VAISHNAVI PATTINA SOUHARDHA SAHAKARI SANGHA NIYAMITHA,GANGAVATHI vs. ITO WARD 1, KOPPAL, KOPPAL

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2017-18 Sri Sri Vaishnavi Pattina Souharda Sahakari Vs. Ito, Sangha Niyamita, Ward – 1, Shop No.9 T.A.P.C.M.S Complex, Koppal. C.B.S Gunj Gangavathi Dt- Koppal 583227,Karnataka. Pan : Aalas 9104 P Appellant Respondent Assessee By : Shri. Deepak, Ca Revenue By : Shri. Ashwin D Gowda, Addl. Cit(Dr)(Itat), Bangalore. Date Of Hearing : 28.07.2025 Date Of Pronouncement : 31.07.2025

E R Per Laxmi Prasad Sahu, Accountant Member : This is an appeal filed by the assessee against CIT(A)’s order videDIN & Order No: ITBA/NFAC/S/250/2024-25/1074332934(1)dated 11.03.2025. 2. Briefly stated the facts of the case are that assessee is registered in the name and style of Sri Sri Vaishnavi Pattina Souhardha Sahakari Sangha Niyamitha under the Karnataka Souharda Sahakari

ITO, WARD-6(3)(1), BANGALORE, BANGALORE vs. SAHAKARA NAGAR CREDIT CO-OPERATIVE SOCIETY LIMITED, BANGALORE

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2017-18

E-Stamp Commission Rs. 35,000/- (ii) Other income Rs. 50,236/- (iii) Commission Rs. 620/- (iv) Pickmy Commission Rs. 65,439/- Total Rs. 1,51,295/- 7. The AO held that these receipts are not attributable to the eligible business, therefore the same are not eligible for deduction under section 80P(2)(a)(i) of the Act and accordingly

M/S. NAGINI CO-OPERATIVE CREDIT SOCIETY LIMITED,BENGALURU vs. INCOME TAX OFFICER, WARD- 6(2)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2016-17 M/S. Nagini Co-Operative Credit Society Ltd., Vs. Ito, No.569, 3Rd Stage, 4Th Block, 80 Ft. Road, Ward – 6[2][1], Basaveswara Nagar, Bengaluru. Bengaluru – 560 079. Pan : Aacan 5552 H Appellant Respondent Appellant By : Shri. V. Srinivasan, Advocate Respondent By : Shri. Kannan Narayanan, Jcit(Dr)(Itat), Bengaluru Date Of Hearing : 04.08.2021 Date Of Pronouncement : 10.08.2021 O R D E R Per N.V. Vasudevanthis Is An Appeal By The Assessee Against The Order Dated 30.08.2019 Of Cit(A), Bengaluru-6, Bengaluru, Relating To Assessment Year 2016-17. 2. The Assessee Is A Society Registered Under The Karnataka State Co- Operative Societies Act, 1959. For Assessment Year 2016-17, The Assessee Filed Return Of Income & Claimed Deduction Of A Sum Of Rs.1,70,31,095/- Under Section 80P(2)(1)(I) Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’).

E R Per N.V. Vasudevan, Vice President This is an appeal by the assessee against the order dated 30.08.2019 of CIT(A), Bengaluru-6, Bengaluru, relating to Assessment Year 2016-17. 2. The assessee is a society registered under the Karnataka State Co- operative Societies Act, 1959. For Assessment Year 2016-17, the assessee filed return of income and claimed

MENASI SEEMEYA GROUP,SIRSI vs. CIT, HUBLI

Appeals of the assessee are allowed

Bench: Shri N.V.Vasudevan & Shri Abraham P George

E R PER SHRI ABRAHAM P GEORGE, AM; Assessee, in these appeals assails the orders of the CIT under section 263 of the Income-tax Act, 1961 ( in short ‘The Act’) whereby he held the assessments done on the assessee under section 143(3) of the Act, to be erroneous in so far as it was prejudicial to the interest

M/S. LALITHAMBA PATTINA SOUHARDA SAHAKARI NIYAMITA ,GADAG vs. INCOME-TAX OFFICER, WARD-1, GADAG

In the result, all the appeals of the assessee are partly allowed

section and assessee is eligible for\ndeduction u/s. 80P on such interest income. The AO has wrongly\nclassified interest income has income from other sources without\nallowing full deduction on the cost of funds and administrative\nexpenses. He further submitted that the AO is not justified in stating\nthat the appellant has already claimed benefit of expenditure in\ncomputing

SHRI SHANKARLING CO-OPERATIVE CREDIT SOUHARDA SAHAKARI NIYAMIT,BELAGAVI vs. INCOME TAX OFFICER, WARD- 1(3), BELAGAVI

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

Bench: Shri George George K

E R This appeal at the instance of the assessee is directed against CIT(A)’s order dated 02.12.2019. The relevant assessment year is 2012-2013. 2. There is a delay of 207 days in filing this appeal. The assessee has filed a petition for condonation of delay. I have perused the reasons stated for belated filing of the appeal

M/S. TUNGABHADRA PATTINA SOUHARDHA SAHAKARI NIYAMITHA,RAICHUR vs. THE INCOME TAX, OFFICER, WARD-1, RAICHUR

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

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

E R Per Chandra Poojari, AM These appeals by the assessee are directed against two different orders of the CIT(A) for assessment years 2017-2018 and 2018-2019, dated 25.10.2021 and 02.11.2021, respectively. 2. The first common ground raised by the assessee reads as under:- “2. That the ld.CIT(A) erred in confirming the order of AO and denying

M/S. TUNGABHADRA PATTINA SOUHARDHA SAHAKARI NIYAMITHA,RAICHUR vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

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

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

E R Per Chandra Poojari, AM These appeals by the assessee are directed against two different orders of the CIT(A) for assessment years 2017-2018 and 2018-2019, dated 25.10.2021 and 02.11.2021, respectively. 2. The first common ground raised by the assessee reads as under:- “2. That the ld.CIT(A) erred in confirming the order of AO and denying

SHRI SALESHWAR PATTIN SAHAKARI SANGH NIYAMIT,BAGALKOT vs. INCOME TAX OFFICER, WARD- (1), BANGALORE

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

Bench: Shri Chandra Poojariassessment Year : 2013-14

E R This appeal by the assessee is against the order dated 12.12.2019 of the CIT(Appeals), Hubballi, relating to assessment year 2013-14. 2. The concise grounds of appeal raised by the assessee are as follows:- “1. The Ld. Commissioner of Income Tax (Appeals) erred in law as well as on facts in rejecting the genuine claim