THE KUNDARA PANCHAYATH SERVICE COOPERATIVE BANK LTD,KOLLAM vs. INCOME TAX OFFICER, WARD 4, KOLLAM

In the result, appeals filed by the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

disallowing the claim u/s 80P of the Act? 7. We have heard the rival submissions and perused the materials available on record. We are of the considered opinion that the issue in dispute is squarely covered in the case Pr. CIT v. Peroorkada Service Co-Operative Bank Ltd.(2022) 442 ITR 141 held by Hon’ble Kerala High Court wherein

AYUR GREEN AYURVEDA HOSPITALS PRIVATE LIMITED,MALAPPURAM vs. DCIT, CPC, BENGALURU, BENGALURU

In the result, the assessee’s appeal is dismissed

Bench: Shri Sanjay Arora & Dr. S. Seethalakshmiayurgreen Ayurveda Hospsitals Vs Dcit, Private Limited Cpc, Door No. 1/301 Ayurgreen Bengaluru. Ayurveda Hospitals, Kaladi Mlp Edappal, Malappuram-679585. (Appellant) (Respondent) Pan No. Aaica 4294 M

13. The provisions of section 143(1)(a) read as under:- “143(1) Where a return has been made under section 139, or in response to a notice under sub-section (1) of Section143, such return shall be processed in the following manner, namely;- (a) The total income or loss shall be computed after making the following adjustments, namely

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

2) of the Act and that the Assessee had sufficient surplus funds and that the investments being stock in trade no disallowance can be made u/s.14-A of the Act. 16. After considering the rival contentions, we are of the view that the issue of disallowance u/s.14A of the Act has to be remanded to the AO for fresh consideration

VADAKKEVILA SERVICE CO-OPERATIVE BANK LTD,KOLLAM vs. THE ITO, KOLLAM

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowing the interest paid to members u/s 40(a)(ia) of the Act without appreciating that the tax is not required to be deducted u/s 194A of the Act if the interest is paid to members of the co- operative society.” 3. We have given thoughtful consideration to the Revenue’s foregoing objection to the assessee’s sec.80P deduction claim

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD ,PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD,PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,MG ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance of deduction claimed by the Assessee under Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty

THE DCIT, KOCHI vs. M/S.SFO TECHNOLOGIES P. LTD, ALUVA

In the result, this appeal filed by Revenue in ITA

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

13, Appeal No. CIT(A), Kochi-1/10169/2016-17 for ay:2013-14, Appeal No. CIT(A),Kochi-1/10558/2016-17 for ay: 2014-15 andAppeal No. CIT(A), Kochi-1/10200/2018-19 for ay:2016-17 , all passed by learnedCommissioner of Income Tax (Appeals), Kochi-1(hereinafter called "theCIT(A)"),the appellate proceedingshad arisen before learned CIT(A) from separate assessment orders

THE DCIT, KOCHI vs. M/S.SFO TECHNOLOGIES P. LTD, ERNAKULAM

In the result, this appeal filed by Revenue in ITA

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

13, Appeal No. CIT(A), Kochi-1/10169/2016-17 for ay:2013-14, Appeal No. CIT(A),Kochi-1/10558/2016-17 for ay: 2014-15 andAppeal No. CIT(A), Kochi-1/10200/2018-19 for ay:2016-17 , all passed by learnedCommissioner of Income Tax (Appeals), Kochi-1(hereinafter called "theCIT(A)"),the appellate proceedingshad arisen before learned CIT(A) from separate assessment orders

THE DCIT, KOCHI vs. M/S.SFO TECHNOLOGIES P. LTD, ALUVA

In the result, this appeal filed by Revenue in ITA

Bench: Shri George Mathan, Jm & Shri Ramit Kochar, Am

13, Appeal No. CIT(A), Kochi-1/10169/2016-17 for ay:2013-14, Appeal No. CIT(A),Kochi-1/10558/2016-17 for ay: 2014-15 andAppeal No. CIT(A), Kochi-1/10200/2018-19 for ay:2016-17 , all passed by learnedCommissioner of Income Tax (Appeals), Kochi-1(hereinafter called "theCIT(A)"),the appellate proceedingshad arisen before learned CIT(A) from separate assessment orders