DCIT vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

2) and 11(5) of the Act. Here again the AO found that the assessee had not filed Form no. 10 as required by Sub-section 5 of Section 11 of the Act. The assessee thus having failed to follow the prescribed procedure, the AO made an addition of Rs.1,94,11,605/-. 4. The assessee, feeling aggrieved, challenged both

THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

2) and 11(5) of the Act. Here again the AO found that the assessee had not filed Form no. 10 as required by Sub-section 5 of Section 11 of the Act. The assessee thus having failed to follow the prescribed procedure, the AO made an addition of Rs.1,94,11,605/-. 4. The assessee, feeling aggrieved, challenged both

DEPUTY COMMISSIONER OF INCOME TAX, YAMUNANAGAR vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

2) and 11(5) of the Act. Here again the AO found that the assessee had not filed Form no. 10 as required by Sub-section 5 of Section 11 of the Act. The assessee thus having failed to follow the prescribed procedure, the AO made an addition of Rs.1,94,11,605/-. 4. The assessee, feeling aggrieved, challenged both

THE MULLANPUR GARIBDAS CO-OP MULTIPURPOSE SOCIETY,MULLANPUR vs. PR. CIT-II, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed deduction under section 80P on the interest income earned from the FDs maintained in the banks. It was stated that however, the assessee was not eligible for deduction under section 80P on this interest income. It was stated that the issue had not been examined by the AO, nor the assessee had offered any detail regarding claiming deduction

THE MULLANPUR GARIBDAS CO-OP MULTIPURPOSE SOCIETY,MOHALI vs. PR. CIT-II, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed deduction under section 80P on the interest income earned from the FDs maintained in the banks. It was stated that however, the assessee was not eligible for deduction under section 80P on this interest income. It was stated that the issue had not been examined by the AO, nor the assessee had offered any detail regarding claiming deduction

THE MULLANPUR GARIBDAS CO-OP MULTIPURPOSE SOCIETY,MOHALI vs. DCIT, C-6(1), MOHALI

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed deduction under section 80P on the interest income earned from the FDs maintained in the banks. It was stated that however, the assessee was not eligible for deduction under section 80P on this interest income. It was stated that the issue had not been examined by the AO, nor the assessee had offered any detail regarding claiming deduction

THE JAGADHRI CO-OPERATIVE MARKETING CUM PROCESSING SOCIETY LTD.,JAGADHRI vs. THE PR.CIT, PANCHKULA

In the result, the appeal of the assessee is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

5. In view of the foregoing, it is held that the assessment order dated 13.03.2021 passed by the Assessing Officer is erroneous in so far as it is prejudicial to the interest of the revenue as per clause (d) of Explanation 2 to Section 263 of the Act.” 15. We have heard the rival submissions and perused the material available

THE BALDUHAK CO-OPERATIVE AGRICULTURE SERVICE SOCIETY LTD.,HAMIRPUR vs. ITO, WARD, HAMIRPUR

Bench: Us Are That The Assessee Is A Cooperative

section 80P(2)(d) of the Act and same was disallowed and the income was brought to tax under the head “income from other sources”. 5

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

5,30,940/- was paid which is evident from the expenditure account of the society. The CC Limit against Fixed deposit was utilized by the assessee for the purpose of its business or running thrift and credit society for payment to its members. It was submitted that the said issue is no longer res-interga as the said issue

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

5,30,940/- was paid which is evident from the expenditure account of the society. The CC Limit against Fixed deposit was utilized by the assessee for the purpose of its business or running thrift and credit society for payment to its members. It was submitted that the said issue is no longer res-interga as the said issue

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं . / ITA No.160, 161 & 162/ Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18, 2012-13 & 2013-14 The Jyoti Co-operative Non Agricultural Thrift & Credit Society Ltd. Sirmour, Solan, HP-173025 स्थायी लेखा सं. / PAN NO: AAABT1453G अपीलार्थी/Appellant बनाम The ITO H.P Ward-Nahan, Sirmour प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, Advocate राजस्व की ओर से / Revenue by : Dr. Ranjeet K

5,30,940/- was paid which is evident from the expenditure account of the society. The CC Limit against Fixed deposit was utilized by the assessee for the purpose of its business or running thrift and credit society for payment to its members. It was submitted that the said issue is no longer res-interga as the said issue

THE MANDEBAR PRIMARY AGRICULTURE CO-OPERATIVE SOCIETY LIMITED,YAMUNANAGAR vs. ITO, WARD -5, YAMUNA NAGAR

Bench: Us Are That The Assessee Is A Primary Agricultural Cooperative Society Engaged In Providing Credit Facilities To Its Members For Agricultural Operations & Procurement Of Fertilizers For The Purpose Of Supplying It To Its Members. 3.1 During The Year Under Consideration, It Filed Its Return Of Income Claiming Deduction Under Section 80P Amounting To Rs. 40,87,123/- & Which Includes Deduction Amounting To Rs. 29,44,171/- In Respect Of Interest Income On Deposits Placed With Yamunanagar District Central Cooperative Bank.

disallowance of the deduction claimed which on appeal has been allowed by the Tribunal and thereafter, the question of law which was proposed by the Revenue for the opinion of the Hon’ble High Court was “whether on the facts and circumstances of the case, the Tribunal is right in law in allowing deduction under section 80P(2

DCIT, C-V, LUDHIANA vs. M/S HERO CYCLES LTD., LUDHIANA

In the result, appeal of the Department is dismissed and the appeal of the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 588/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 The DCIT C-V, Ludhiana बनाम M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 473/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana बनाम The ACIT C-V, Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P

5] iii) ACB India Ltd v ACIT, 374 ITR 108 (Del) For purpose of section 14A, instead of taking into account total investment, investment attributable to dividend was required to be adopted an thereafter disallowance was to be arrived. 33. The Ld. Counsel of assessee also argued that suo-moto disallowance can also be challenged. Hon'ble SC and many

THE AMBALA CO-OP MARKETING CUM PROCESSING SOCIETY LTD,AMBALA vs. ITO WARD-1 AMBALA, AMBALA CANTT

disallowance of deduction amounting to Rs. 16,21,458/- under section 80P(2)(d) of the Act, 2. None appeared on behalf of the assessee nor has any adjournment application been filed. Considering the issue involved in the matter, it was decided to proceed based on the written submissions dt. 31/07/2025 filed by the assessee’s Counsel, Shri Sanjeev Mishra

M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

2 pertains to the issue of the ld. CIT(A) having deleted the addition of export commission of Rs.2,20,71,855/- paid by the assessee to NRIs without deducting TDS. 5. The AO disallowed the expenditure on the commission on exports amounting to Rs.2,20,71,855/-, invoking the provisions of Section

DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

2 pertains to the issue of the ld. CIT(A) having deleted the addition of export commission of Rs.2,20,71,855/- paid by the assessee to NRIs without deducting TDS. 5. The AO disallowed the expenditure on the commission on exports amounting to Rs.2,20,71,855/-, invoking the provisions of Section

M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

2 pertains to the issue of the ld. CIT(A) having deleted the addition of export commission of Rs.2,20,71,855/- paid by the assessee to NRIs without deducting TDS. 5. The AO disallowed the expenditure on the commission on exports amounting to Rs.2,20,71,855/-, invoking the provisions of Section

DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

2 pertains to the issue of the ld. CIT(A) having deleted the addition of export commission of Rs.2,20,71,855/- paid by the assessee to NRIs without deducting TDS. 5. The AO disallowed the expenditure on the commission on exports amounting to Rs.2,20,71,855/-, invoking the provisions of Section

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. HARYANA STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LIMITED, PANCHKULA

In the result, the present appeal of the Revenue is allowed for statistical purposes

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

2)(d) in respect of dividend received from investments in co-operative institutions. The AO disallowed both claims holding that (i) the godowns were used in connection with trading activity with FCI, KRIBHCO, and CWC and not purely let out, and (ii) the dividend income was exempt under section 10(34) and thus disallowable under section 14A. 5