THE CUDDALORE DISTRICT CENTRAL CO-OP BANK LTD.,CUDDALORE vs. DCIT CUDDALORE CIRCLE, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

D E R PER MAHAVIR SINGH, VICE PRESIDENT: The appeal by the Revenue in ITA No.981/CHNY/2020 is arising out of order of the Commissioner of Income Tax (Appeals), Puducherry in ITA No.47,48/CIT(A)-PDY/2017-18 dated 31.08.2020. The assessment was framed by the DCIT, Villupuram Circle, Villupuram, for the assessment year 2008-09 u/s.143(3) of the Income

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

D E R PER MAHAVIR SINGH, VICE PRESIDENT: The appeal by the Revenue in ITA No.981/CHNY/2020 is arising out of order of the Commissioner of Income Tax (Appeals), Puducherry in ITA No.47,48/CIT(A)-PDY/2017-18 dated 31.08.2020. The assessment was framed by the DCIT, Villupuram Circle, Villupuram, for the assessment year 2008-09 u/s.143(3) of the Income

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPRUAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

D E R PER MAHAVIR SINGH, VICE PRESIDENT: The appeal by the Revenue in ITA No.981/CHNY/2020 is arising out of order of the Commissioner of Income Tax (Appeals), Puducherry in ITA No.47,48/CIT(A)-PDY/2017-18 dated 31.08.2020. The assessment was framed by the DCIT, Villupuram Circle, Villupuram, for the assessment year 2008-09 u/s.143(3) of the Income

THE VILLUPURAM DISTRICT CENTRAL COOPERTATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

D E R PER MAHAVIR SINGH, VICE PRESIDENT: The appeal by the Revenue in ITA No.981/CHNY/2020 is arising out of order of the Commissioner of Income Tax (Appeals), Puducherry in ITA No.47,48/CIT(A)-PDY/2017-18 dated 31.08.2020. The assessment was framed by the DCIT, Villupuram Circle, Villupuram, for the assessment year 2008-09 u/s.143(3) of the Income

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-II,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

D E R PER MAHAVIR SINGH, VICE PRESIDENT: The appeal by the Revenue in ITA No.981/CHNY/2020 is arising out of order of the Commissioner of Income Tax (Appeals), Puducherry in ITA No.47,48/CIT(A)-PDY/2017-18 dated 31.08.2020. The assessment was framed by the DCIT, Villupuram Circle, Villupuram, for the assessment year 2008-09 u/s.143(3) of the Income

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

D E R PER MAHAVIR SINGH, VICE PRESIDENT: The appeal by the Revenue in ITA No.981/CHNY/2020 is arising out of order of the Commissioner of Income Tax (Appeals), Puducherry in ITA No.47,48/CIT(A)-PDY/2017-18 dated 31.08.2020. The assessment was framed by the DCIT, Villupuram Circle, Villupuram, for the assessment year 2008-09 u/s.143(3) of the Income

INDIAN OVERSEAS BANK,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee appeals ITA Nos

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

D E R PER G. PAVAN KUMAR, JUDICIAL MEMBER: The appeals filed by the assessee bank are directed against different orders of the Commissioner of Income Tax –Large Taxpayer Unit, dt 12.02.2015 for the assessment years 2010-2011 ITA No.496 & 497/Mds/2015 :- 2 -: and 2011-12 passed u/s. 263 and 250 of the Income Tax Act, 1961 (herein after referred

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

D. Anand, Advocate, referring to show cause notice issued u/s.274 r.w.s.271(1)(c) of the Act dated 26.07.2021 submitted that, the AO has issued a printed form of show cause notice without specifying under which limb the assessee is charged to levy penalty u/s.271(1)(c) of the Act, which shows non- application of mind

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

D. Anand, Advocate, referring to show cause notice issued u/s.274 r.w.s.271(1)(c) of the Act dated 26.07.2021 submitted that, the AO has issued a printed form of show cause notice without specifying under which limb the assessee is charged to levy penalty u/s.271(1)(c) of the Act, which shows non- application of mind

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

D' BENCH, CHENNAI\nश्री महावीर सिंह, उपाध्यक्ष एवं श्री एस. आर.रघुनाथा, लेखा सदस्य के समक्ष\nBEFORE SHRI MAHAVIR SINGH, HON'BLE VICE PRESIDENT AND SHRI S. R. RAGHUNATHA, HON'BLE ACCOUNTANT MEMBER\nआयकर अपीलसं./ITA Nos.: 800 & 799/Chny/2023\nनिर्धारण वर्ष / Assessment Years: 2013-14 & 2014-15\nAssistant Commissioner of Income Tax, Central Circle -1(1), Chennai.\n(अपीलार्थी/Appellant

AA 293 PANAHALLI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,ERODE vs. THE INCOME TAX OFFICER, WARD 2(1), ERODE

In the result, the appeals filed in ITA Nos

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.2020, 2021 & 2022/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Aa 293 Panahalli Primary Agricultural Vs. The Income Tax Officer, Cooperative Credit Society Limited, Ward 2(1), 1, Panakkahally, Thalavady Post, Erode. Erode 638 461. [Pan: Aacaa1566A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. A. Vijayalakshmi, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 11.11.2025 आदेश /O R D E R Per Bench: These Three Appeals Filed By The Assessee Are Directed Against Separate Orders All Dated 27.06.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21 Towards Disallowance Of Deduction Claimed Under Section 80P Of The Income Tax Act, 1961 [“Act” In Short], Levy Of Penalty Under Section 270A Of The Act & Levy Of Penalty Under Section 272(1)(D) Of The Act By Rejecting The Prayer Of Condonation Of Delay In Filing The Appeals Before The Ld. Cit(A).

disallowance of deduction claimed under section 80P of the Income Tax Act, 1961 [“Act” in short], levy of penalty under section 270A of the Act and levy of penalty under section 272(1)(d

AA 293 PANAHALLI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,ERODE vs. THE INCOME TAX OFFICER, WARD 2(1), ERODE

In the result, the appeals filed in ITA Nos

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.2020, 2021 & 2022/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Aa 293 Panahalli Primary Agricultural Vs. The Income Tax Officer, Cooperative Credit Society Limited, Ward 2(1), 1, Panakkahally, Thalavady Post, Erode. Erode 638 461. [Pan: Aacaa1566A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. A. Vijayalakshmi, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 11.11.2025 आदेश /O R D E R Per Bench: These Three Appeals Filed By The Assessee Are Directed Against Separate Orders All Dated 27.06.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21 Towards Disallowance Of Deduction Claimed Under Section 80P Of The Income Tax Act, 1961 [“Act” In Short], Levy Of Penalty Under Section 270A Of The Act & Levy Of Penalty Under Section 272(1)(D) Of The Act By Rejecting The Prayer Of Condonation Of Delay In Filing The Appeals Before The Ld. Cit(A).

disallowance of deduction claimed under section 80P of the Income Tax Act, 1961 [“Act” in short], levy of penalty under section 270A of the Act and levy of penalty under section 272(1)(d

AA 293 PANAHALLI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,ERODE vs. THE INCOME TAX OFFICER WARD 2(1), ERODE

In the result, the appeals filed in ITA Nos

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.2020, 2021 & 2022/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Aa 293 Panahalli Primary Agricultural Vs. The Income Tax Officer, Cooperative Credit Society Limited, Ward 2(1), 1, Panakkahally, Thalavady Post, Erode. Erode 638 461. [Pan: Aacaa1566A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. A. Vijayalakshmi, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 11.11.2025 आदेश /O R D E R Per Bench: These Three Appeals Filed By The Assessee Are Directed Against Separate Orders All Dated 27.06.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21 Towards Disallowance Of Deduction Claimed Under Section 80P Of The Income Tax Act, 1961 [“Act” In Short], Levy Of Penalty Under Section 270A Of The Act & Levy Of Penalty Under Section 272(1)(D) Of The Act By Rejecting The Prayer Of Condonation Of Delay In Filing The Appeals Before The Ld. Cit(A).

disallowance of deduction claimed under section 80P of the Income Tax Act, 1961 [“Act” in short], levy of penalty under section 270A of the Act and levy of penalty under section 272(1)(d

SRC PROJECTS PVT. LTD.,SALEM vs. ACIT, CIRCLE-1, SALEM

Accordingly, the appeal filed by the assessee is dismissed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2358/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 V. M/S. Src Projects Pvt. Ltd., The Acit, 4-B, Lakshmipuram, Circle-(1), Gandhi Road, Salem-636 007. Salem. [Pan: Aagcs 3528 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

D E R PER MANU KUMAR GIRI, JM: The captioned appeal filed by the assessee is directed against order of the Ld. Commissioner of Income Tax (Appeals), ADDL/JCIT (A)-2, Visakhapatnam [‘CIT(A)’ in short] dated 23.06.2025 for Assessment Year 2017-18. 2. Brief facts of the case are that "the assessee is a Private Limited Company. For the assessment

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

272\n(Bombay) and CIT v Green Infra Ltd [2017] 78\ntaxmann.com 340 to the same proposition that once the\nidentity of the shareholders is proven and the amounts are\nreceived through banking channels, share capital cannot\nbe assessed under Section 68 even if shares were issued\nat excess premium. The assessee also quoted the Delhi\nHigh Court decision

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

d) and (e) 4,52,90,296 (g) Provision made for Bad and Doubtful Debts by the Bank 22,20,00,000 (h) Least of (f) or (g) allowable as deduction u/s 36(1)(viia) 4,52,90,296 :- 23 -: ITA Nos.1671, 1801, 1802, 1803, 1804, 2034 & 2035/Mds/2014 3.6. The assessee is therefore entitled to a deduction

CITY UNION BANK LIMITED,KUMBAKONAM vs. JCIT, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

d) and (e) 4,52,90,296 (g) Provision made for Bad and Doubtful Debts by the Bank 22,20,00,000 (h) Least of (f) or (g) allowable as deduction u/s 36(1)(viia) 4,52,90,296 :- 23 -: ITA Nos.1671, 1801, 1802, 1803, 1804, 2034 & 2035/Mds/2014 3.6. The assessee is therefore entitled to a deduction

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

d) and (e) 4,52,90,296 (g) Provision made for Bad and Doubtful Debts by the Bank 22,20,00,000 (h) Least of (f) or (g) allowable as deduction u/s 36(1)(viia) 4,52,90,296 :- 23 -: ITA Nos.1671, 1801, 1802, 1803, 1804, 2034 & 2035/Mds/2014 3.6. The assessee is therefore entitled to a deduction

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

d) and (e) 4,52,90,296 (g) Provision made for Bad and Doubtful Debts by the Bank 22,20,00,000 (h) Least of (f) or (g) allowable as deduction u/s 36(1)(viia) 4,52,90,296 :- 23 -: ITA Nos.1671, 1801, 1802, 1803, 1804, 2034 & 2035/Mds/2014 3.6. The assessee is therefore entitled to a deduction