CHIKKAMUDNOOR MILK PRODUCERS CO-OPERATIVE SOCIETY LIMITED, ,CHIKKAMUDNOOR vs. INCOME TAX OFFICER, WARD-1 , PUTTUR

In the result appeal of the assessee is dismissed

Bench: Shri Prashant Maharishiassessment Year : 2019-20

80P by a co-operative society, when the return of income is filed beyond the due date prescribed under Section 139(1), when the existence of a specific clause, Section 143(1)(a)(v), which was amended with effect from April 1, 2021, to address such disallowances

SRI SOWRABHA MAHILA PATTINA SAHAKARA SANGHA ,TUMKUR vs. INCOME TAX OFFICER, WARD-1, TIPTUR

The appeals are dismissed, however

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2019-20

80P by a co-operative society, when the return of income is filed beyond the due date prescribed under Section 139(1), when the existence of a specific clause, Section 143(1)(a)(v), which was amended with effect from April 1, 2021, to address such disallowances

SRI PANATI VIDYANATH REDDY ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

disallowance can be made as per section 36(1)(va) r.w.s. 2(24)(x) of the Act. Hence, respectfully following the judgment of Hon’ble Supreme court cited (supra), the arguments of the assessee is not acceptable. 8.1 The Ld. A.R. has also raised on the issue that the disallowance/addition cannot be made u/s 14-3(1

M/S. NIRMAL ENVIRO SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

disallowance can be made as per section 36(1)(va) r.w.s. 2(24)(x) of the Act. Hence, respectfully following the judgment of Hon’ble Supreme court cited (supra), the arguments of the assessee is not acceptable. 8.1 The Ld. A.R. has also raised on the issue that the disallowance/addition cannot be made u/s 14-3(1

KOME KORAVADI VIVIDODDESHA SAHAKARI SANGHA NIYAMITHA,UDUPI vs. INCOME TAX OFFICER, WARD-1, UDUPI

1,\nKoravadi, Kumbashi, Kundapura Taluk,\nUdupi.\nUdupi - 576 257.\nPAN – AAAAK 5006 F\nAPPELLANT\nRESPONDENT\nAssessee by\n:\nShri Akshaya K.S, CA\nRevenue by\n:\nShri Ganesh R Ghale – Advocate, Standing\nCounsel for Revenue\nDate of hearing\n:\n25.02.2026\nDate of Pronouncement\n:\n12.03.2026\nORDER\nPER WASEEM AHMED, ACCOUNTANT MEMBER:\nThe present appeal has been instituted by the assessee against

MASS FAB TECHNOLOGIES,BANGALORE vs. CIT(APPEALS), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojariassessment Year: 2020-21

disallowance can be made as per section 36(1)(va) r.w.s. 2(24)(x) of the Act. Hence, respectfully following the judgment of Hon’ble Supreme court cited (supra), the arguments of the assessee is not acceptable. 8.1 The Ld. A.R. has also raised on the issue that the disallowance/addition cannot be made u/s 14-3(1

ITEK PACKZ,BANGALORE vs. INCOME TAX OFFICER, WARD-3(2)(4), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojariassessment Year: 2020-21

disallowance can be made as per section 36(1)(va) r.w.s. 2(24)(x) of the Act. Hence, respectfully following the judgment of Hon’ble Supreme court cited (supra), the arguments of the assessee is not acceptable. 8.1 The Ld. A.R. has also raised on the issue that the disallowance/addition cannot be made u/s 14-3(1

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance can be made as per section 36(1)(va) r.w.s. 2(24)(x) of the Act. Hence, respectfully following the judgment of Hon’ble Supreme court cited (supra), the arguments of the assessee is not acceptable. 8.1 The Ld. A.R. has also raised on the issue that the disallowance/addition ITA Nos.294 to 296/Bang/2023 Nandi Hospitality Services Pvt. Ltd., Bangalore

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance can be made as per section 36(1)(va) r.w.s. 2(24)(x) of the Act. Hence, respectfully following the judgment of Hon’ble Supreme court cited (supra), the arguments of the assessee is not acceptable. 8.1 The Ld. A.R. has also raised on the issue that the disallowance/addition ITA Nos.294 to 296/Bang/2023 Nandi Hospitality Services Pvt. Ltd., Bangalore

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance can be made as per section 36(1)(va) r.w.s. 2(24)(x) of the Act. Hence, respectfully following the judgment of Hon’ble Supreme court cited (supra), the arguments of the assessee is not acceptable. 8.1 The Ld. A.R. has also raised on the issue that the disallowance/addition ITA Nos.294 to 296/Bang/2023 Nandi Hospitality Services Pvt. Ltd., Bangalore

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

disallowance of business loss and addition of e-stamping income were also remanded for verification.", "result": "Partly Allowed", "sections": [ "80P(2)(a)(i)", "80P(2)(d)", "80P(4)", "43B", "37(1

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

disallowed the\nclaim under section 80P (2) (a) (i) of the act on the interest\nincome earned by the assessee on the loans and credits extended\nby the assessee.\n2.6 The Ld.AO held that the assessee was not a\nprimary agricultural credit society nor a primary co-\noperative agricultural or a rural development bank. It was held\nthat, the assessee

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

disallowance of its claim for deduction under Section 80P(2)(a)(i) and (d) of the Income Tax Act. The Assessing Officer (AO) held that the assessee was not a primary agricultural credit society and was hit by Section 80P(4) of the Act, denying the claim.", "held": "The Tribunal held that the assessee, being a cooperative society registered under

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

disallowed the\nclaim under section 80P (2) (a) (i) of the act on the interest\nincome earned by the assessee on the loans and credits extended\nby the assessee.\n2.6 The Ld.AO held that the assessee was not a\nprimary agricultural credit society nor a primary co-\noperative agricultural or a rural development bank. It was held\nthat, the assessee

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

disallowance.", "held": "The Tribunal held that the assessee is not a bank under the Banking Regulation Act and thus Section 80P(4) does not apply. It allowed deduction for interest earned from credit facilities extended to members (including nominal/associate members) under Section 80P(2)(a)(i). However, interest earned from loans to employees was to be treated as income from

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

disallowed the\nclaim under section 80P (2) (a) (i) of the act on the interest\nincome earned by the assessee on the loans and credits extended\nby the assessee.\n2.6 The Ld.AO held that the assessee was not a\nprimary agricultural credit society nor a primary co-\noperative agricultural or a rural development bank. It was held\nthat, the assessee

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

1 in taking the above\nview. Further, the AO for Assessment Year 2017-18 held that interest\nincome earned on investments with Co-operative Banks is to be assessed as\n\"Income from Other Sources\" and same cannot be allowed as deduction\nunder sections 80P(2)(a)(i) or 80P(2)(d) of the Act. In taking the above\nview

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

disallowed the\nclaim under section 80P (2) (a) (i) of the act on the interest\nincome earned by the assessee on the loans and credits extended\nby the assessee.\n2.6 The Ld.AO held that the assessee was not a\nprimary agricultural credit society nor\na primary co-\noperative agricultural or a rural development bank. It was held\nthat, the assessee