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

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

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

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

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, all the appeals filed by the assessee are allowed

47 of 74\nITA Nos.642 to 645/Bang/2024\nhas made disallowance under Section 14A on a wrong notion that\nthe disallowance is presumptive in nature even when the\nexpenditure is not actually incurred.\n\n6. 6. It is submitted that the Learned DR has not brought anything contrary\nto the above submissions in his objections dated 30.01.2025.\nTherefore, the disallowance made

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

47 of 48\nITA Nos. 1052 to 1060/Bang/2023\n20.4 Identical issue has been analysed hereinabove while\nconsidering the interest earned by the assessee from staff loan.\nWe rely on the observations made in para 16.3 and hold that the\nincome earned by the assessee from E stamping cannot be\nconsidered for the purpose of deduction under section 80P(2

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

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

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

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

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

47 of 48\nITA Nos. 1052 to 1060/Bang/2023\n20.4 Identical issue has been analysed hereinabove while\nconsidering the interest earned by the assessee from staff loan.\nWe rely on the observations made in para 16.3 and hold that the\nincome earned by the assessee from E stamping cannot be\nconsidered for the purpose of deduction under section 80P(2

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

section 80P.\n\n(h)The revenue from e-stamping is 2,11,580 as opposed to\nthe Appellant's total revenue of ₹171,68,04,506. Thus, the\ne-stamping revenue constitutes a measly 0.01% of the\nAppellant's total revenue. Thus, being inconsequential and\nimmaterial, these activities cannot recharacterize the\noperations of the Appellant and deprive the Appellant

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

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

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

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

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

47 has held that provisions of section 80P(4) of the Act is to be\nread as a proviso to section 80P(2)(a)(i) of the Act which specifically\nallows deduction to Co-operative Societies engaged in the business\nof providing credit facilities to its members and not Co-operative\nBanks. The relevant portion of the judgment is reproduced

M/S. THE BHAVASARA KSHATRIYA CO-OPERATIVE SOCIETY LIMITED,MYSURU vs. INCOME TAX OFFICER, WARD-2(1), MYSURU

disallowance of deduction\nu/s 80P of the Act, the assessee has preferred this appeal.\n5.\nThe ld. D.R. relied on the order of lower authorities. 6. We have heard\nthe rival submissions and perused the materials available on record. The ld.\nA.R. for the assessee has submitted detailed written submissions, which are\nkept on record. First of all, the claim

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

2), the disallowance under section 14A should be restricted to Rs. 37,16,131 being 5% of salary cost of CFO, 50% of salary cost of employees handling treasury functions and 10% of salary cost of CFC as voluntarily disallowed by the appellant under section 14A. 5.2 The ld CIT(A) in his order stated that the argument

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE vs. M/S INFOSYS LIMITED , BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

2), the disallowance under section 14A should be restricted to Rs. 37,16,131 being 5% of salary cost of CFO, 50% of salary cost of employees handling treasury functions and 10% of salary cost of CFC as voluntarily disallowed by the appellant under section 14A. 5.2 The ld CIT(A) in his order stated that the argument

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

section 80P(2)(a)(i) or 80P(2)(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

M/S. NAVODAYA GRAMA VIKAS CHARITABLE TRUST,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, BANGALORE

In the result, the appeal filed by assessee stands allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18 M/S. Navodaya Grama Vikas Charitable Trust, The Deputy #14-7-1005, Scdcc Commissioner Of Bank Ltd., Income Tax, Head Office Building, Central Circle – 1, Kodialbail, Vs. Mangaluru. Mangaluru – 575 003. Pan: Aaatn7594E Appellant Respondent : Shri V. Srinivasan, Advocate & Assessee By Ms. Sunaina Bhatia, Ca Revenue By : Shri D.K. Mishra, Cit Dr Date Of Hearing : 07-07-2023 Date Of Pronouncement : 31-08-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 07.03.2022 Passed By Ld.Cit(A)-2, Panaji For A.Y. 2017-18 On Following Grounds Of Appeal: “1. The Orders Of The Authorities Below In So Far As They Are Against The Appellant Are Opposed To Law. Equity, Weight Of Evidence. Probabilities, Facts & Circumstances Of The Case. 2. The Learned Cit [A] Is Not Justified In Upholding The Disallowance Of The Exemption Claimed U/S.11 Of The Act

disallowance of the exemption claimed u/s.11 of the Act, Page 2 on the ground that the activities of the appellant are hit by the provisions of section 13[8] rws the proviso to section 2[15] of the Act, under the facts and in the circumstances of the appellant's case. 3. The learned CIT[A] has erred in holding

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

47,431/- on the investment made by the assessee in co-operative banks by relying on the judgment of Hon’ble jurisdictional High Court in case of Totgars Cooperative Sale Society reported in (2017) 83 taxmann.com 140 & (2017) 78 taxmann.com 179. The Ld.AR of the assessee submitted that the case of the assessee is covered by the jurisdictional High 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

47,431/- on the investment made by the assessee in co-operative banks by relying on the judgment of Hon’ble jurisdictional High Court in case of Totgars Cooperative Sale Society reported in (2017) 83 taxmann.com 140 & (2017) 78 taxmann.com 179. The Ld.AR of the assessee submitted that the case of the assessee is covered by the jurisdictional High Court