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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

4) of the Act even though without any amendment in Section 80P(2)(d) of the Act is sufficient to deny the claim of the respondent assessee for deduction under Section 80P(2)(d) of the Act. The only exception is that of a primary agricultural credit society. The depository Kanara District Central Bank Limited in the present case

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

4) of the Act even though without any amendment in Section 80P(2)(d) of the Act is sufficient to deny the claim of the respondent assessee for deduction under Section 80P(2)(d) of the Act. The only exception is that of a primary agricultural credit society. The depository Kanara District Central Bank Limited in the present case

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

4) of the Act even though without any amendment in Section 80P(2)(d) of the Act is sufficient to deny the claim of the respondent assessee for deduction under Section 80P(2)(d) of the Act. The only exception is that of a primary agricultural credit society. The depository Kanara District Central Bank Limited in the present case

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

4) of the Act even though without any amendment in Section 80P(2)(d) of the Act is sufficient to deny the claim of the respondent assessee for deduction under Section 80P(2)(d) of the Act. The only exception is that of a primary agricultural credit society. The depository Kanara District Central Bank Limited in the present case

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

4) of the Act even though without any amendment in Section 80P(2)(d) of the Act is sufficient to deny the claim of the respondent assessee for deduction under Section 80P(2)(d) of the Act. The only exception is that of a primary agricultural credit society. The depository Kanara District Central Bank Limited in the present case

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

80P, Doddakannellii, Income-tax, Sarjapur Road, Circle-7(1)(2) Bangalore 560 035 Bangalore. PAN: AAACW 0387R APPELLANT RESPONDENT Appellant by : Shri Sandeep Huilgol, Advocate Respondent by : Dr. Manjunath Karkihallli, CIT(DR)(ITAT), Bengaluru. Date of hearing : 03.04.2023 Date of Pronouncement : 14.06.2023 O R D E R Per Laxmi Prasad Sahu, Accountant Member The appeal filed by the assessee

SRI RAMASEVA BAHUSARA KSHARIYA CO-OP. SOCIETY LIMITED,SHIMOGA vs. PR. CIT, BENGALURU-1, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21 M/S. Sri Ramaseva Bahusara Kshariya Co-Op. Society Ltd. 01, Ramanna Setty Park Spm Road, Doddapete So Vs. Principal Cit Shimoga 577 202 Bengaluru-1 Karnataka Pan No :Aaajs0083P Appellant Respondent Appellant By : Sri V. Srinivasan, A.R. Respondent By : Sri Kiran D., D.R. Date Of Hearing : 11.12.2025 Date Of Pronouncement : 30.01.2026

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed.] (3) Not withstanding anything contained in sub-section

BHAVANA CO-OP CREDIT SOCIETY NIYAMITA ,SIRSI vs. INCOME TAX OFFICER, WARD-1, SIRSI

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 15 of 31 [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised

GONIKOPPAL PRIMARY RURAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-3, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 15 of 31 [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised

M/S. ALLSTATE INDIA PRIVATE LIMITED ,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year: 2018-19

Pricing Agreement, the assessee has filed modified ITR u/s 139 r.w.s. 92CD of the Income- tax Act,1961 ['the Act' for short] on 19.10.2020 declaring income of Rs.23,19,09,830/-. The other statutory notices were issued to the assessee. 2.1 The assessee company is engaged in providing software development services including testing, infrastructure support and other related services

BHARATH CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. PR. CIT, BANGALORE -1, BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed.] (3) Not withstanding anything contained in sub-section

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri George George K. & Shri Chandra Poojari

80P of the Act are interpreted in the following manner: '1. … The Tribunal referred the following question for the opinion of the High Court: "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the deduction under Section 80-P of the Income Tax Act should be allowed before