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

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 concealment of income. 3. Brief facts

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

In the result, the appeal of the assessee is allowed

80P(2) in respect of income derived from\nits business activity including interest income earned from fixed deposits\nwith other cooperative banks / societies. We have noted that the Ld.AO\non page 3 of his order in para 4.3 given a finding that the assessee is\nPACC society engaged in the business of financial assistance to its\nmembers. It is also

MEGNANAPURAM PACCS,TIRUCHENDUR vs. PCIT,, MADURAI

80P\nof the Act ought not to have been accepted while passing the re-assessment\norder, thereby rendering the same to be erroneous in so far as it is prejudicial to\nthe interest of the revenue, within the ambit of provisions in Section 263 of the\n:-12-:\nITA. No:895/Chny/2025\nAct and accordingly pleaded for dismissal of the appeal

THE COIMBATORE CO-OPERATIVE HOUSING SOCIETY LTD,COIMBATORE vs. ITO, NCW 1(1), COIMBATORE

Bench: Shri Aby T. Varkey & Shri S.R. Raghunathaआयकर अपील सं./Ita No.2593/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 V. The Coimbatore Co-Operative- The Income Tax Officer, Housing Society Ltd., Non-Corporate Ward-1(1), 15, Gopalapuram, 2Nd Street, Coimbatore. Coimbatore – 641 018. [Pan: Aabat 0297 N]

reassessment order dated 20.03.2023 u/s.143/263 of the Act, wherein he disallowed the interest earned by assessee on its money kept with the Axis Bank to the tune of Rs.11,25,431/-. Thus, the AO disallowed the claim made by the assessee u/s.80P(2)(a)(i) of the Act. On appeal, the Ld.CIT(A) has confirmed the action

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

reassessment proceedings, the assessee cannot claim any new benefits or fresh claims, because the reopening of assessment is in the benefits of the revenue. Therefore, he submitted that the CIT(A) erred in allowing relief to the assessee and their order should be reversed. 8. The Ld. Counsel for the assessee, on the other hand submits that the assessee

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

reassessment proceedings, the assessee cannot claim any new benefits or fresh claims, because the reopening of assessment is in the benefits of the revenue. Therefore, he submitted that the CIT(A) erred in allowing relief to the assessee and their order should be reversed. 8. The Ld. Counsel for the assessee, on the other hand submits that the assessee

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

reassessment proceedings, the assessee cannot claim any new benefits or fresh claims, because the reopening of assessment is in the benefits of the revenue. Therefore, he submitted that the CIT(A) erred in allowing relief to the assessee and their order should be reversed. 8. The Ld. Counsel for the assessee, on the other hand submits that the assessee

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

reassessment proceedings, the assessee cannot claim any new benefits or fresh claims, because the reopening of assessment is in the benefits of the revenue. Therefore, he submitted that the CIT(A) erred in allowing relief to the assessee and their order should be reversed. 8. The Ld. Counsel for the assessee, on the other hand submits that the assessee

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

reassessment proceedings, the assessee cannot claim any new benefits or fresh claims, because the reopening of assessment is in the benefits of the revenue. Therefore, he submitted that the CIT(A) erred in allowing relief to the assessee and their order should be reversed. 8. The Ld. Counsel for the assessee, on the other hand submits that the assessee

K.K. CHINNAPUTHUR PACCS,TIRUPPUR vs. ITO, WARD-2(4), TIRUPPUR

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.828 & 829/Chny/2025 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 K.K. Chinnaputhur Primary Agricultural Vs. The Income Tax Officer, Co-Operative Credit Society, 52/37A, Ward 2(4), Reddipalayam, Chinnapudhur Post, Tiruppur. Dharapuram, Tiruppur 638 656. [Pan:Aabak3665K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 04.06.2025 घोषणा की तारीख /Date Of Pronouncement : 30.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 29.08.2024 & 18.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 20015-16 & 2016-17 Respectively.

2,15,92,860 – ₹.95,13,185/-], the same was considered as income from undisclosed sources under section 69A r.w.s. 115BBE of the Act. 7. The Assessing Officer further noted that the assessee has shown gross total income at ₹.7,56,308/- and claimed entire income as 4 I.T.A. Nos.828 & 829/Chny/25 deduction under section 80P

K.K.CHINNAPUTHUR PACCS,TIRUPPUR vs. ITO, WARD-2(4), TIRUPPUR

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.828 & 829/Chny/2025 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 K.K. Chinnaputhur Primary Agricultural Vs. The Income Tax Officer, Co-Operative Credit Society, 52/37A, Ward 2(4), Reddipalayam, Chinnapudhur Post, Tiruppur. Dharapuram, Tiruppur 638 656. [Pan:Aabak3665K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 04.06.2025 घोषणा की तारीख /Date Of Pronouncement : 30.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 29.08.2024 & 18.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 20015-16 & 2016-17 Respectively.

2,15,92,860 – ₹.95,13,185/-], the same was considered as income from undisclosed sources under section 69A r.w.s. 115BBE of the Act. 7. The Assessing Officer further noted that the assessee has shown gross total income at ₹.7,56,308/- and claimed entire income as 4 I.T.A. Nos.828 & 829/Chny/25 deduction under section 80P

ORUVANDUR PACB LTD,NAMAKKAL vs. ITO, WARD 2, NAMAKKAL, NAMAKKAL

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2117/Chny/2025 Assessment Years: 2019-20 Oruvandur Pacb Ltd, Income Tax Officer, Orunvandur Po, Ward-2, Namakkal, Namakkal Tamil Nadu-637015, [Pan: Aaaao0407C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.T.S.Lakshmi Venkataraman, C.A प्रत्यर्थी की ओर से /Revenue By : Mr.Saujanya Ranjan, Irs सुनवाई की तारीख/Date Of Hearing : 24.09.2025 घोषणा की तारीख /Date Of Pronouncement : 25.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

section 80P of the Act. The Ld. Counsel argued that it is assailing the order of Ld.CIT(A) both on legal grounds as well as on the merits of the case. As the legal ground of the appellant assessee strikes at the very root of the reassessment order u/s. 147 r.w.s. 144 dated 13.03.2024, we deem it appropriate to adjudicate

MADURA COATS EMPLOYEES AND PUBLIC SERVICE CO-OP HOUSING SOCIETY LTD.,TIRUNELVELI vs. ITO, WARD-4,, TIRUNELVELI

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.: 2345/Chny/2025 िनधा"रण वष"/Assessment Year:2016-17 Maduracoats Employees & The Income Tax Officer, Public Service Co-Op Ward 4, Housing Society Ltd., Vs. Tirunelveli Ambasamudram, Agasthiyarpatti S.O, Agasthiyarpatti, Tirunelveli – 627428. Pan: Aaiam 5076B (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar (Erode), Advocate ""यथ" क" ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit सुनवाई क" तारीख/Date Of Hearing : 30.10.2025 घोषणा क" तारीख/Date Of Pronouncement : 10.11.2025

reassessment order passed without issuing a notice under section 143(2) is void and bad in law, following the ratio of the decisions in 226 Taxman 103 (Madras) and ITA No.1198/CHNY/2023 dated 21.08.2024. The ld. counsel futher contended that the directions issued by JCIT under section 144A on 24.09.2021 having not been cancelled, the subsequent direction dated 29.09.2021 is invalid

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

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment proceedings was initiated vide notice issued u/s.148 of the Act dated 20.03.2014 and served on the assessee. The AO for issuance of notice recorded reasons as under:- “2. I. The assessee bank had claimed the following deductions while computing its total income during the previous year 2007-08 relevant to A.Y.2008-09. Provision for Standard Assets released: Rs. 2

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

reassessment proceedings was initiated vide notice issued u/s.148 of the Act dated 20.03.2014 and served on the assessee. The AO for issuance of notice recorded reasons as under:- “2. I. The assessee bank had claimed the following deductions while computing its total income during the previous year 2007-08 relevant to A.Y.2008-09. Provision for Standard Assets released: Rs. 2

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

reassessment proceedings was initiated vide notice issued u/s.148 of the Act dated 20.03.2014 and served on the assessee. The AO for issuance of notice recorded reasons as under:- “2. I. The assessee bank had claimed the following deductions while computing its total income during the previous year 2007-08 relevant to A.Y.2008-09. Provision for Standard Assets released: Rs. 2

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

reassessment proceedings was initiated vide notice issued u/s.148 of the Act dated 20.03.2014 and served on the assessee. The AO for issuance of notice recorded reasons as under:- “2. I. The assessee bank had claimed the following deductions while computing its total income during the previous year 2007-08 relevant to A.Y.2008-09. Provision for Standard Assets released: Rs. 2

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

reassessment proceedings was initiated vide notice issued u/s.148 of the Act dated 20.03.2014 and served on the assessee. The AO for issuance of notice recorded reasons as under:- “2. I. The assessee bank had claimed the following deductions while computing its total income during the previous year 2007-08 relevant to A.Y.2008-09. Provision for Standard Assets released: Rs. 2

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

reassessment proceedings was initiated vide notice issued u/s.148 of the Act dated 20.03.2014 and served on the assessee. The AO for issuance of notice recorded reasons as under:- “2. I. The assessee bank had claimed the following deductions while computing its total income during the previous year 2007-08 relevant to A.Y.2008-09. Provision for Standard Assets released: Rs. 2