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

68,500 Bank Ltd 29,76,150 Tumkur Grain Merchant co-op 2,87,500 Bank Ltd 32,72,084 Bharat Co-op Bank (Mumbai)ltd 9,23,847 2,15,220 Subramanyeshwara co-op Bank Ltd 2,50,000 ITA Nos.2347 & 2348/Bang/2024 & CO Nos.4 & 5/Bang/2025 M/s. Bangalore Credit Co-operative Society Ltd., Bangalore Page 16 of 44 Bharat

M/S. SHRI MAHISHASURAMARDINI URBAN CO-OPERATIVE CREDIT SOCIETY LIMITED,HAVERI vs. INCOME TAX OFFICER, WRD-1, HAVERI

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

Bench: Shri Chandra Poojari

80P of the Income-tax Act. We thus answer substantial questions of law B and C formulated and enumerated above.” 10.3 I have gone through the judgments relied upon by both the parties. In my opinion, the assessment year involved in the present appeal is A.Y. 2017-2018 and the judgment of the Hon’ble Kerala High Court

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

Bench: SHRI WASEEM AHMED, ACCOUNTANT MEMBER\nAND\nSHRI KESHAV DUBEY, JUDICIAL MEMBER\nITA No.210/Bang/2024\nAssessment Year: 2017-18\nM/s Canara Bank\nFM wing, Head Office,\n112, J.C. Road\nBangalore 560002\nVs.\nDCIT\nCircle-2(1)(1)\nBangalore\nPAN NO : AAACC6106G\nAPPELLANT\nRESPONDENT\nITA No.222/Bang/2024\nAssessment Year: 2017-18\nDCIT\nCircle-2(1)(1)\nBangalore\nVs.\nM/s Canara Bank\nFM wing, Head Office,\n112, J.C. Road\nBangalore 560 002\nAPPELLANT\nRESPONDENT\nITA No.1154/Bang/2023\nAsses

C\"BENCH: BANGALORE\nBEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER\nAND\nSHRI KESHAV DUBEY, JUDICIAL MEMBER\nITA No.210/Bang/2024\n Assessment Year: 2017-18\nM/s Canara Bank\nFM wing, Head Office,\n112, J.C. Road\nBangalore 560002\nVs.\nDCIT\nCircle-2(1)(1)\nBangalore\nPAN NO : AAACC6106G\nAPPELLANT\nRESPONDENT\nITA No.222/Bang/2024\n Assessment Year: 2017-18\nDCIT\nCircle-2(1)(1)\nBangalore

MINORITY CO OP CREDIT SOCIETY LTD, BAGALKOT,BAGALKOT vs. ITO W(1), BAGALKOT, BAGALKOT

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

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2017-18

80P(2)(a)(iii) of the Act.” 3.10 It is directed that in the event it is found that the interest is earned by the assessee from such commercial/cooperative banks that fall within the definition of “banking company’ as per section 2(c), Section 5(b) and holds license under section 22 of the Banking Regulation

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

c) On facts and circumstances of the case and in law, the Learned CIT(A)/(NFAC) has erred in deleting the disallowance u/s 80P(2)(d) of the IT Act of Rs.3,42,99,582/- without taking into its consideration the decision of the Hon'ble HC of Karnataka in Pr.CIT, Hubballi Vs the Totgars Co-operative Sale Society Limited

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HUBBALLI vs. M/S. KARNATAKA VIKAS GRAMEEN BANK LIMITED, DHARWAD

In the result, the appeal of assessee is partly allowed and the appeal of the revenue is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

c) is being issued separately. 6. Sections 22 and 32 of the Regional Rural Banks Act, 1976 provides as under:— 22. Regional Rural Bank to be deemed to be a cooperative society for purpose of the Income-tax Act, 1961.- For the purpose of the Income-tax Act, 1961 (43 of 1961), or any other enactment for the time

M/S KARNATAKA VIKAS GRAMEENA BANK,DHARWAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HUBBALLI

In the result, the appeal of assessee is partly allowed and the appeal of the revenue is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

c) is being issued separately. 6. Sections 22 and 32 of the Regional Rural Banks Act, 1976 provides as under:— 22. Regional Rural Bank to be deemed to be a cooperative society for purpose of the Income-tax Act, 1961.- For the purpose of the Income-tax Act, 1961 (43 of 1961), or any other enactment for the time

BELVE VYAVASAYA SEVA SAHAKARI SANGHA LIMITED ,UDUPI vs. INCOME TAX OFFICER, WARD-2, UDUPI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

2)(C) on income from PDS, the same is not allowable as deduction for the reason that ROI was not filed (within time allowed) thereby disentitling the appellant u/s 80A(5) of the Act. As for the provisions made by the appellant (discussed supra) and claimed as deduction, they are in the nature of unascertained liabilities and thus not allowed

BELVE VYAVASAYA SEVA SAHAKARI SANGHA LIMITED,UDUPI vs. INCOME TAX OFFICER, WARD-2, UDUPI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

2)(C) on income from PDS, the same is not allowable as deduction for the reason that ROI was not filed (within time allowed) thereby disentitling the appellant u/s 80A(5) of the Act. As for the provisions made by the appellant (discussed supra) and claimed as deduction, they are in the nature of unascertained liabilities and thus not allowed

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

68,500 Tumkur Grain Merchant co-op Bank Ltd 32,72,084 2,87,500 Bharat Co-op Bank (Mumbai)ltd 9,23,847 2,15,220 Subramanyeshwara co-op Bank Ltd 2,50,000 Bharat Co-op Bank Ltd 7,12,500 Grain Merchant Co-op Bank Ltd 5,62,500 1,03,463 Karnataka State Co-operative Apex

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

68,149/- was to be treated as salary as per the circular of the DT and no disallowance ought to have been made under section 4o(a)(ia) of the act, on the facts and circumstances of the case. The authorities below filed to appreciate that the audit fees c) of Rs. 1,00,000/-was paid

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

68,82,138/-. The ld. AO has raised a demand of Rs.1086,07,00,024/- after charging interest u/s 234B of the Act as per the normal provisions of the Act. 3.2 Aggrieved by the order of the ld. AO, the assessee went in appeal before ld. CIT(A)/NFAC. The ld. CIT(A) partly allowed the appeal

INCOME TAX OFFICER, WARD-1(1), C R BUILDING HUBLI vs. THE NATIONALWELFARE URBAN CO-OP CREDIT SOCIETT LIMITED, DHARWAD

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year: 2017-18

section 80P(2)(a)(i) of the Act with regard to the income earned from the assessee’s dealings with its regular members. It is ordered accordingly. Ground Nos.(c) & (d) (Issue of addition of Rs.1,47,17,500/- u/s 68

SRI BRAMARAMBA PATTINA SOUHARDA SHAKARI SANGHA NIYAMITHA,MASKI vs. INCOME TAX OFFICER, WARD-1, RAICHUR

In the result, the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

80P are as under- mentioned in pages 7 86 8 of the impugned assessment order: Amount Sl.No. Name of the Bank (in Rs.) Interest from Co-operative Banks (i) BDCC Bank Ltd. 14,72,000 Beelagi Pattina Sahakara Bank (ii) 40,14,376 Ltd (iii) Mudgal Urban Bank Ltd 22,50,945 (iv) RDCC Bank

SIDDHI VINAYAKA SOUHARDHA PATTINA SAHAKARI NIYAMITA,KALABURAGI vs. INCOME TAX OFFICER, WARD-1 & TPS, GULBARGA

The appeals of the assessee are allowed for statistical purposes

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

68,93,785/- in co- operative banks on which it has earned Rs.35,18,407/- as interest and the interest has been claimed as deduction u/s. 80P(2)(a)(i). The deduction claimed by the assessee under chapter VIA u/s. 80P(2)(a)(i) was examined by the assessing officer and he concluded that the deduction 80P is available only

BHAVASAR NAMDEV SIMPI SAMAJ SAHAKAR SANGH LTD,DANDELI vs. INCOME TAX OFFICER, HUBLI

In the result, we partly allow the appeal of the assessee

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2017-18

68,438/- and ld. AR of the assessee submitted that the assessee was not required to file return of income because of its Page 6 of 8 income below the threshold limit of tax and assessee is eligible for deduction under section 80P(2). We reject this arguments of the ld. AR since the deduction can be claimed under

M/S FARMERS AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LTD.,,KOPPA vs. ITO, MYSORE

In the result, the assessee’s appeal for assessment year

Bench: Smt. Asha Vijayaraghavan, Jm (Smc)

c) of the IT Act. The assessee submitted before the AO that in the case of M/s Totgar’s Co-Operative Sale Society Ltd Vs ITO 322 ITR 283(SC), the assessee was in the business of marketing agricultural produce of its members and earned income from huge bank deposits made out of its sales. This interest was claimed

SRI. KALABHAIRAWESHWARA MULTI-PURPOSE CO-OP SOCIETY LTD., ,CHIKKAMAGALURU vs. INCOME TAX OFFICER, WARD-1, , CHIKKAMAGALURU

In the result, appeal filed by the assessee is dismissed

Bench: Shri George George K & Ms. Padmavathi. Sr Assessment Year : 2018-19 Sri Kalabhairaveshwara Multi-Purpose Co- Vs. Ito, Operative Society Ltd., Ward Officer, K. M. Road,Chikmagalur District Office Ward – 1, S. O. 577 101, Karnataka. Chikmagaluru. Pan : Aapas 3058 L Appellant Respondent Assessee By : Shri. Mahesh R. Uppin, Advocate Revenue By : Ms. Neha Sahay, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 16.10.2024 Date Of Pronouncement : 17.10.2024

68,097/- in Chikmagalur District Page 2 of 8 Central Co-operative Bank Ltd. Therefore, notice under section 148 of the Act, was issue on 24.03.2022. In response to the notice issued under section 148 of the Act, assessee filed its return of income on 25.04.2022 declaring Nil income. Assessment was completed under section 147 r.w.s. 144B