UDAYA SOUHARDA CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-5(1)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

gains or capital arising from the business of carrying on banking activities or providing credit facilities to its members, then the interest income earned therefrom shall be treated as business income attributable to such activity and the assessee shall be allowed deduction under section 80P(2)(a)(i) of the Act in accordance with law. However, if it is found

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

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

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

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

Bench: Shri George George K & Shri Waseem Ahmed

section 80P(2)(d) of the Act, the Revenue has filed the present appeals before the Tribunal. The learned DR relied on the grounds raised. 8. The learned AR, on the other hand, supported the findings of the CIT(A). 9. We have heard the rival submissions and perused the material on record. The Hon'ble Supreme Court

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

section 80P(2)(d) of the Act, the Revenue has filed the present appeals before the Tribunal. The learned DR relied on the grounds raised. 8. The learned AR, on the other hand, supported the findings of the CIT(A). 9. We have heard the rival submissions and perused the material on record. The Hon'ble Supreme Court

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

Bench: Shri George George K & Shri Waseem Ahmed

section 80P(2)(d) of the Act, the Revenue has filed the present appeals before the Tribunal. The learned DR relied on the grounds raised. 8. The learned AR, on the other hand, supported the findings of the CIT(A). 9. We have heard the rival submissions and perused the material on record. The Hon'ble Supreme Court

SRI JIHVESHWARA CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD 2(2)(5), BANGALORE, BANGALORE

In the result, this issue in ITA No

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

section 80P(2)(d) of the Act." 22. Again, the Division Bench of Punjab and Haryan High Court in still a later decision reported in the same volume of ITR in the case of CIT v. Punjab State Co-operative Agricultural Development Bank Ltd. [2016] 389 ITR 607/76 taxmann.com 307 (Punj. & Har.) concurred with the aforesaid view of the Gujarat

SRI JIHVESHWARA CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD 2(2)(5), BANGALORE, BANGALORE

In the result, this issue in ITA No

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

section 80P(2)(d) of the Act." 22. Again, the Division Bench of Punjab and Haryan High Court in still a later decision reported in the same volume of ITR in the case of CIT v. Punjab State Co-operative Agricultural Development Bank Ltd. [2016] 389 ITR 607/76 taxmann.com 307 (Punj. & Har.) concurred with the aforesaid view of the Gujarat

SRI JIHVESHWARA CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD 2(2)(5), BANGALORE

In the result, this issue in ITA No

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

section 80P(2)(d) of the Act." 22. Again, the Division Bench of Punjab and Haryan High Court in still a later decision reported in the same volume of ITR in the case of CIT v. Punjab State Co-operative Agricultural Development Bank Ltd. [2016] 389 ITR 607/76 taxmann.com 307 (Punj. & Har.) concurred with the aforesaid view of the Gujarat

SRI JIHVESHWARA CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD 2(2)(5), BANGALORE, BANGALORE

In the result, this issue in ITA No

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

section 80P(2)(d) of the Act." 22. Again, the Division Bench of Punjab and Haryan High Court in still a later decision reported in the same volume of ITR in the case of CIT v. Punjab State Co-operative Agricultural Development Bank Ltd. [2016] 389 ITR 607/76 taxmann.com 307 (Punj. & Har.) concurred with the aforesaid view of the Gujarat

SRI JIHVESHWARA CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD 2(2)(5), BANGALORE, BANGALORE

In the result, this issue in ITA No

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

section 80P(2)(d) of the Act." 22. Again, the Division Bench of Punjab and Haryan High Court in still a later decision reported in the same volume of ITR in the case of CIT v. Punjab State Co-operative Agricultural Development Bank Ltd. [2016] 389 ITR 607/76 taxmann.com 307 (Punj. & Har.) concurred with the aforesaid view of the Gujarat

SHARANABASAVESHWAR CREDIT SOUHARD SAHAKRI NI HALINGALI,BAGALKOT vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-1, BIJAPUR

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

section 80P(2)(d) of the Act." 22. Again, the Division Bench of Punjab and Haryana High Court in still a later decision reported in the same volume of ITR in the case of CIT v. Punjab State Co-operative Agricultural Development Bank Ltd. [2016] 389 ITR 607/76 taxmann.com 307 (Punj. & Har.) concurred with the aforesaid view of the Gujarat

SANGAM CO-OP CREDIT SOCIETY,BAGALKOT vs. INCOME-TAX OFFICER WARD-2 , BAGALKOT

In the result, both the appeals by the assessee are 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

SANGAM CO-OP CREDIT SOCIETY,BAGALKOT vs. INCOME-TAX OFFICER WARD 1& TPS, BAGALKOT

In the result, both the appeals by the assessee are 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

M/S. PRATHAMIKA KRUSHI PATTINA SAHAKARA NIYAMITA,HOSAPETE vs. INCOME TAX OFFICER, WARD-2, BALLARI

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

Bench: Shri Laxmi Prasad Sahuprathamika Krishi Pattina Vs The Income Tax Officer Sahakara Sangha Niymit Ward - 2 No. 350, Ward No. 15, Hospet 583201 Amaravathi Village, Hospet Tq. Ballari - 583201 Pan – Aaajp0326N (Appellant) (Respondent) Assessee By: Shri Siva Prasad Reddy, Irs (Retd) Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 13.02.2023 Date Of Pronouncement: 14.02.2023 O R D E R Per: Laxmi Prasad Sahu, A.M. This Is An Appeal Filed By The Assessee Against The Order Passed By The Learned Cit(A)/Nfac, Delhi In Appeal Din & Order No. Itba/Nfac/S/ 250//2022-23/1047496227(1) Dated 18.11.2022 For Ay 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. The Impugned Assessment Order Made U/S 143(3) Of The Act Dated, 25-11-2019, Is Arbitrary & Opposed To The Facts Of The Case & The Principles Of Natural Justice & Therefore, The Same Is Liable To Be Vacated As Void. 2. The Learned Cit(A) Failed To Appreciate: (I) That The Interest Income Accruing From The Investments Made In Statutory Compliance Of The Provisions Of The State Co-Operative Societies Act, 1959 Is Eligible For The Deduction As Business Income U/S 80P(2)(A)(I) Of The Act.

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

M/S. BHARATHI CO-OPERATIVE CREDIT SOCIETY LTD,BENGALURU vs. INCOME TAX OFFICER, WARD-7(2)(3), BENGALURU

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

section 80P(4) of the I.T.Act. As regards the interest income of Rs.26,34,597 received by the assessee and assessed as income from other sources, the CIT(A) confirmed the view taken by the A.O. 5. Aggrieved by the order of the CIT(A), the assessee has filed the present appeal before the Tribunal. The assessee has filed