SHRI. SHANTHISAGAR CO OP CREDIT SOCIETY LIMITED,HUBLI vs. INCOME TAX OFFICER, WARD-2(1), HUBLI

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

d) of the Act on the interest amount of Rs. 47,692/- earned from deposit with the SUCO Bank. Further, the AO noted that the said interest amount of Rs. 47,689/- is 1.4% of gross receipt of the assessee for the year under consideration. Therefore, only proportionate amount shall be disallowed from the assessee claim of deduction under section

INCOME TAX OFFICER,WARD-1, HOSPET vs. GAYATRI PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA, HOSPET, HOSPET

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

capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains of the business of providing credit facilities to its members only. The society is not carrying on any separate

INCOME TAX OFFICER, WARD-7(2)(1), BENGALURU, BANGALORE vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED , BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

d) of section 80P of the Act would not apply to the facts and circumstances of the case. In view of the above, he prayed that the disallowance of assessee Society’s claim of deduction of interest income earned from co-operative banks may be restored. 13. The ld. A.R. on the other hand in his written submissions, submitted

INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

In the result both the appeals of the Revenue as well as\nCos of the Assessee for the Asst

d) of section 80P of the Act would\nnot apply to the facts and circumstances of the case. In view of the\nabove, he prayed that the disallowance of assessee Society's claim\nof deduction of interest income earned from co-operative banks may\nbe restored.\n\n13. The ld. A.R. on the other hand in his written submissions,\nsubmitted

INCOME TAX OFFICER, WARD-1, UDUPI vs. KAMBADAKONE RYTARA SEVA SAHAKARI SANGHA LTD, UPPUNDA

d) of the Act or to be classified as\n“income from other sources” and taxed accordingly.\n10.6.2\nWe also take a note of the fact that the deposit in\nquestion was not voluntarily made by the assessee society for\ninvestment purposes but were instead statutorily mandated by the\nKarnataka State Co-operative Society Act, 1959. As per section

INCOME TAX OFFICER, WARD 1, UDUPI, UUPI vs. KAMBADAKONE RYTARA SEVA SAHAKARI SANGHA LTD, UDUPI

d) of the Act or to be classified as\n“income from other sources” and taxed accordingly.\n10.6.2 We also take a note of the fact that the deposit in\nquestion was not voluntarily made by the assessee society for\ninvestment purposes but were instead statutorily mandated by the\nKarnataka State Co-operative Society Act, 1959. As per section

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

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

capital of the society and shall be deposited into Page 3 of 15 ITA Nos. 25 to 27/Bang/2025 the co -operative Bank hence there is a Business nexus to the earning of interest income hence eligible for deduction under section 80P(2)(a)(i) The reliance is placed on following case laws a. Lankapalli PACS Ltd V/s ITO, held

NAGINI COOPERATIVE CREDIT SOCIETY LIMITED ,BANGALORE vs. INCOME TAX OFFICER, WARD-6(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

capital of the society and shall be deposited into Page 3 of 15 ITA Nos. 25 to 27/Bang/2025 the co -operative Bank hence there is a Business nexus to the earning of interest income hence eligible for deduction under section 80P(2)(a)(i) The reliance is placed on following case laws a. Lankapalli PACS Ltd V/s ITO, held

NAGINI COOPERATIVE CREDIT SOCIETY LIMITED ,BANGALORE vs. INCOME TAX OFFICER, WARD-6(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

capital of the society and shall be deposited into Page 3 of 15 ITA Nos. 25 to 27/Bang/2025 the co -operative Bank hence there is a Business nexus to the earning of interest income hence eligible for deduction under section 80P(2)(a)(i) The reliance is placed on following case laws a. Lankapalli PACS Ltd V/s ITO, held

THE BELTHANGADY CO-OPERATIVE AGRICULTURAL SANGHA LIMITED,BELTHANGADY vs. INCOME TAX OFFICER, WARD-1, , PUTTUR

In the result, the appeal of the assessee is hereby partly allowed\nfor statistical purposes

d) of the Act. Hence, the contention of the assessee that\nthe cooperative banks are also cooperative society is not tenable. Hence,\nthe impugned interest income is not eligible for deduction.\n18. The next contention of the assessee is whether the deposits with\nSchedule Bank or Co-Operative Bank were made out of compulsory\nrequirement under the provision of Karnataka

INCOME TAX OFFICER, WARD 1, UDUPI, UDUPI vs. BRAHMAVARA VYAVASAYA SEVA, BRAHMAVARA

In the result, the appeals filed by Revenue are allowed and the COs\nfiled by the assessee are allowed for statistical purposes

section 80P(2)(d) of the Act. In this context, the learned CIT(A)\nrelied on the judgment of the Hon'ble jurisdictional High Court in the case\nof PCIT Vs. Totgars Co-operative Sale Society [2017] 83 taxmann.com\n140 (Karnataka) and also the Order of the Tribunal in the case of Totgars\nCo-operative Sale Society Ltd., Vs. ACIT

INCOME-TAX OFFICER, WARD-1, UDUPI, UDUPI vs. BRAHMAVARA VYAVAYASAYA SEVA, BRAHMAVARA

In the result, the appeals filed by Revenue are allowed and the COs\nfiled by the assessee are allowed for statistical purposes

section 80P(2)(d) of the Act. In this context, the learned CIT(A)\nrelied on the judgment of the Hon'ble jurisdictional High Court in the case\nof PCIT Vs. Totgars Co-operative Sale Society [2017] 83 taxmann.com\n140 (Karnataka) and also the Order of the Tribunal in the case of Totgars\nCo-operative Sale Society Ltd., Vs. ACIT

INCOMETAX OFFICER, WARD 1, UDUPI, UDUPI vs. BRAHMAVARA VYAVASAYA SEVA, BRAHMAVARA

In the result, the appeals filed by Revenue are allowed and the COs\nfiled by the assessee are allowed for statistical purposes

section 80P(2)(d) of the Act. In this context, the learned CIT(A)\nrelied on the judgment of the Hon'ble jurisdictional High Court in the case\nof PCIT Vs. Totgars Co-operative Sale Society [2017] 83 taxmann.com\n140 (Karnataka) and also the Order of the Tribunal in the case of Totgars\nCo-operative Sale Society Ltd., Vs. ACIT

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

capital in the audited balance sheet, it is clear that\nPCARD Banks/ primaries are members of the assessee. This\nis also clear from clause 2(n) of chapter II of the bye laws and\nsection 2(a-1-2) and 2(j-4) of the KCS Act. In fact the first\nlisted object of the assessee is to advance loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

capital in the audited balance sheet, it is clear that\nPCARD Banks/ primaries are members of the assessee. This\nis also clear from clause 2(n) of chapter II of the bye laws and\nsection 2(a-1-2) and 2(j-4) of the KCS Act. In fact the first\nlisted object of the assessee is to advance loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME-TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

capital in the audited balance sheet, it is clear that\nPCARD Banks/ primaries are members of the assessee. This\nis also clear from clause 2(n) of chapter II of the bye laws and\nsection 2(a-1-2) and 2(j-4) of the KCS Act. In fact the first\nlisted object of the assessee is to advance loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

capital in the audited balance sheet, it is clear that\nPCARD Banks/ primaries are members of the assessee. This\nis also clear from clause 2(n) of chapter II of the bye laws and\nsection 2(a-1-2) and 2(j-4) of the KCS Act. In fact the first\nlisted object of the assessee is to advance loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

capital in the audited balance sheet, it is clear that\nPCARD Banks/ primaries are members of the assessee. This\nis also clear from clause 2(n) of chapter II of the bye laws and\nsection 2(a-1-2) and 2(j-4) of the KCS Act. In fact the first\nlisted object of the assessee is to advance loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

capital in the audited balance sheet, it is clear that\nPCARD Banks/ primaries are members of the assessee. This\nis also clear from clause 2(n) of chapter II of the bye laws and\nsection 2(a-1-2) and 2(j-4) of the KCS Act. In fact the first\nlisted object of the assessee is to advance loans