K864 MURALI CHENNAMPATTI PRIMARY AGRICULTURE CO-OP CREDIT SOCIETY,ERODE vs. INCOME TAX OFFICER, WARD 2(1), ERODE, ERODE

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

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 681/Chny/2025 िनधा"रण वष"/Assessment Year:2012-13 K864 Murali Chennampatti Primary The Income Tax Officer, Agricultural Co-Op Credit Society, Vs. Ward 2(1), Murali, Murali Post, Erode. Anthiyur Taluk, Erode District – 638 504. Pan: Aabak 3671M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. A. Vijayalakshmi, Ca (Through Virtual Mode) ""यथ" क" ओर से/Respondent By : Ms. Pryati Sharma, Jcit सुनवाई क" तारीख/Date Of Hearing : 03.06.2025 घोषणा क" तारीख/Date Of Pronouncement : 03.06.2025

80A(5) to deny the deduction under Section 80P, despite the appellant's compliance with substantive conditions. The appellant relied the following order of the Hon'ble ITAT Chennai bench i. The ACIT Vs M/s. DAEE Coop T&C Society ITA No.: 3047/CHNY/2019 dt. 10.11.2020 6. The CIT(A) Wrongly initiated penalty proceedings under Section 271(1)(c) without proving

AMMAPALAYAM BASUVAPTTI PRIMARY AGRICULTURAL CO OP CREDIT SOCIETY LIMITED,ERODE vs. THE INCOME TAX OFFICER, WARD 2(1) ERODE, ERODE

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

1) or u/s. 139(4) of the Act. The Assessing Officer had also made additions towards interest earned on fixed deposits with other cooperative banks on the ground that the assessee is not entitled for deduction toward interest income earned from deposits with other cooperative banks. However, since the deduction claimed towards total income has been disallowed, no separate addition

AMMAPALAYAM BASUVAPTTI PRIMARY AGRICULTURAL CO OP CREDIT SOCIETY LIMITED,ERODE vs. THE INCOME TAX OFFICER, WARD 2(1) ERODE, ERODE

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

1) or u/s. 139(4) of the Act. The Assessing Officer had also made additions towards interest earned on fixed deposits with other cooperative banks on the ground that the assessee is not entitled for deduction toward interest income earned from deposits with other cooperative banks. However, since the deduction claimed towards total income has been disallowed, no separate addition

K 0716 RAKKIAPALAYAM PACC,TIRUPUR vs. THE INCOME TAX OFFICER, WARD 1(4) TIRUPUR, TIRUPUR

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1820/Chny/2025

1) or u/s.139(4) of the Act. The Assessing Officer had also made additions towards interest earned on fixed deposits with other cooperative banks on the ground that the assessee is not entitled for deduction toward interest income earned from deposits with other cooperative banks. However, since the deduction claimed towards total income has been disallowed, no separate addition

DCIT, NON CORPORATE CIRCLE-22(1), CHENNAI vs. M/S DAEE COOP T&C SOCIETY, KALPAKKAM

In the result, appeals filed by the revenue for assessment years 2012-13, 2014-15 & 2017-18 and cross objections filed by the assessee for assessment years 2012-13, 2014-15 &

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 592, 593 & 594/Chny/2023 & Co Nos: 23, 24 & 25/Chny/2023 िनधा"रण वष" / Assessment Years: 2012-13, 2014-15 & 2017-18 Deputy Commissioner Of M/S. Dae Employees Coop Thrift Income Tax, V. & Credit Society Ltd, Non Corporate Circle - First Floor, Main Shopping 22(1), Centre, Dae Township, No.7, Ramakrishna Street, Kalpakkam – 603 102. West Tambaram, [Pan: Aaaad-4689-H] Chennai – 45. (अपीलाथ"/Appellant) (Cross Objector) : Shri. Ar V Sreenivasan, Addl. Cit अपीलाथ" क" ओर से/Appellant By Respondent/Cross Objector By : Shri. R. Kumar, Advocate सुनवाई क" तारीख/Date Of Hearing : 26.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 28.06.2023 आदेश /O R D E R

1) or u/s. 139(4) of the Act. The Assessing Officer had also made additions towards interest earned on fixed deposits with other cooperative banks on the ground that the assessee is not entitled for deduction toward interest income earned from deposits with other cooperative banks. However, since the deduction claimed towards total income has been disallowed, no separate addition

DCIT, NON CORPORATE CIRCLE-22(1), CHENNAI vs. M/S DAEE COOP T&C SOCIETY, KALPAKKAM

In the result, appeals filed by the revenue for assessment years 2012-13, 2014-15 & 2017-18 and cross objections filed by the assessee for assessment years 2012-13, 2014-15 &

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 592, 593 & 594/Chny/2023 & Co Nos: 23, 24 & 25/Chny/2023 िनधा"रण वष" / Assessment Years: 2012-13, 2014-15 & 2017-18 Deputy Commissioner Of M/S. Dae Employees Coop Thrift Income Tax, V. & Credit Society Ltd, Non Corporate Circle - First Floor, Main Shopping 22(1), Centre, Dae Township, No.7, Ramakrishna Street, Kalpakkam – 603 102. West Tambaram, [Pan: Aaaad-4689-H] Chennai – 45. (अपीलाथ"/Appellant) (Cross Objector) : Shri. Ar V Sreenivasan, Addl. Cit अपीलाथ" क" ओर से/Appellant By Respondent/Cross Objector By : Shri. R. Kumar, Advocate सुनवाई क" तारीख/Date Of Hearing : 26.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 28.06.2023 आदेश /O R D E R

1) or u/s. 139(4) of the Act. The Assessing Officer had also made additions towards interest earned on fixed deposits with other cooperative banks on the ground that the assessee is not entitled for deduction toward interest income earned from deposits with other cooperative banks. However, since the deduction claimed towards total income has been disallowed, no separate addition

DCIT, NON CORPORATE CIRCLE-22(1), CHENNAI vs. M/S DAEE COOP T&C SOCIETY, KALPAKKAM

In the result, appeals filed by the revenue for assessment years 2012-13, 2014-15 & 2017-18 and cross objections filed by the assessee for assessment years 2012-13, 2014-15 &

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 592, 593 & 594/Chny/2023 & Co Nos: 23, 24 & 25/Chny/2023 िनधा"रण वष" / Assessment Years: 2012-13, 2014-15 & 2017-18 Deputy Commissioner Of M/S. Dae Employees Coop Thrift Income Tax, V. & Credit Society Ltd, Non Corporate Circle - First Floor, Main Shopping 22(1), Centre, Dae Township, No.7, Ramakrishna Street, Kalpakkam – 603 102. West Tambaram, [Pan: Aaaad-4689-H] Chennai – 45. (अपीलाथ"/Appellant) (Cross Objector) : Shri. Ar V Sreenivasan, Addl. Cit अपीलाथ" क" ओर से/Appellant By Respondent/Cross Objector By : Shri. R. Kumar, Advocate सुनवाई क" तारीख/Date Of Hearing : 26.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 28.06.2023 आदेश /O R D E R

1) or u/s. 139(4) of the Act. The Assessing Officer had also made additions towards interest earned on fixed deposits with other cooperative banks on the ground that the assessee is not entitled for deduction toward interest income earned from deposits with other cooperative banks. However, since the deduction claimed towards total income has been disallowed, no separate addition

INTERNATIONAL AGRICULTURAL PROCESSING (P) LTD.,CHENNAI vs. ACIT, MADURAI

In the result, the appeals filed by the assessee for the AYs 2003-04

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the reopening is bad in law. 2. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had fully and truly disclosed all material particulars 3. For that the Completion of the assessment for assessment year 2007-08 does not empower the Assessing

INTERNATIONAL AGRICULTURAL PROCESSING (P) LTD.,CHENNAI vs. ACIT, MADURAI

In the result, the appeals filed by the assessee for the AYs 2003-04

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the reopening is bad in law. 2. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had fully and truly disclosed all material particulars 3. For that the Completion of the assessment for assessment year 2007-08 does not empower the Assessing

INTERNATIONAL AGRICULTURAL PROCESSING (P) LTD.,CHENNAI vs. ACIT, MADURAI

In the result, the appeals filed by the assessee for the AYs 2003-04

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the reopening is bad in law. 2. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had fully and truly disclosed all material particulars 3. For that the Completion of the assessment for assessment year 2007-08 does not empower the Assessing

INTERNATIONAL AGRICULTURAL PROCESSING (P) LTD.,CHENNAI vs. ACIT, MADURAI

In the result, the appeals filed by the assessee for the AYs 2003-04

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the reopening is bad in law. 2. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had fully and truly disclosed all material particulars 3. For that the Completion of the assessment for assessment year 2007-08 does not empower the Assessing

INTERNATIONAL AGRICULTURAL PROCESSING (P) LTD.,CHENNAI vs. ACIT, MADURAI

In the result, the appeals filed by the assessee for the AYs 2003-04

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the reopening is bad in law. 2. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had fully and truly disclosed all material particulars 3. For that the Completion of the assessment for assessment year 2007-08 does not empower the Assessing

INTERNATIONAL AGRICULTURAL PROCESSING (P) LTD.,CHENNAI vs. ACIT, MADURAI

In the result, the appeals filed by the assessee for the AYs 2003-04

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.1251 To 1254, 1407 & 1408/Chny/2016 िनधा"रण वष" /Assessment Years: 2003-04 To 2006-07, 2008-09 & 2007-08 M/S.International Agricultural- V. The Asst. Commissioner- Processing (P) Ltd., Of Income Tax, 332/5-A, Peranai Road, Company Circle-Ii, Musuvanathu Village, Madurai. Nilakottai Taluk, Dindigul-624 219. [Pan: Aaaci 3593 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the reopening is bad in law. 2. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had fully and truly disclosed all material particulars 3. For that the Completion of the assessment for assessment year 2007-08 does not empower the Assessing