THE CHORODE SERVICE CO-OPERATIVE BANK LTD, LL139,CHORODE vs. ITO, WARD-2(2), KOZHIKODE

In the result, appeal of the Revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowing the claim made by the assessee U/s. 80P(2)(a)(i) of the Act. We have perused the ratio laid down by the Hon'ble Apex Court in the case of M/s.Totgars Cooperative Sale Society Ltd (supra) and found that in that case the society is engaged in marketing of the agricultural produce by its members as per section

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

2. The Commissioner (Appeals) is not justified in treating the interest received from cooperative banks as income from other sources and disallowing the claim u/s 8OP. The Commissioner (Appeals) should have appreciated that the appellant is a PrimaryAgricultural CreditSociety engaged in the business ofaccepting deposits from members and providing loans to members. The Commissioner (Appeals) was bound by the decision

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

2. The Commissioner (Appeals) is not justified in treating the interest received from cooperative banks as income from other sources and disallowing the claim u/s 8OP. The Commissioner (Appeals) should have appreciated that the appellant is a PrimaryAgricultural CreditSociety engaged in the business ofaccepting deposits from members and providing loans to members. The Commissioner (Appeals) was bound by the decision

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

2. The Commissioner (Appeals) is not justified in treating the interest received from cooperative banks as income from other sources and disallowing the claim u/s 8OP. The Commissioner (Appeals) should have appreciated that the appellant is a PrimaryAgricultural CreditSociety engaged in the business ofaccepting deposits from members and providing loans to members. The Commissioner (Appeals) was bound by the decision

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

Disallowance of deduction claimed under [section 10AA or under any of the provisions of Chapter VI-A under the heading “C.-Deductions in respect of certain income”, if] the return is furnished beyond the due date specified under sub- section (1) of section 139; or (vi) Addition of income appearing in Form 26AS or Form 16A or Form 16 which

AYYANTHOLE PANCHAYATH SERVICE COOPERATIVE BANK LIMITED 471,KARIYATTUKARA vs. INCOME TAX OFFICER WARD 2(1), THRISSUR

In the result, the appeals filed by the assessee stand allowed

143(3)", "Section 80P(2)(c)(ii)", "Section 80P(2)(a)(i)", "Section 80P(4)"], "issues": "Disallowance of deduction under

AYYANTHOLE PANCHAYATH SERVICE COOPERATIVE BANK LIMITED 471,KARIYATTUKARA vs. INCOME TAX OFFICER WARD 2(1), THRISSUR

In the result, the appeals filed by the assessee stand allowed

disallowance of\ndeduction claimed under Section 80P of the Income-tax Act, 1961. We\ntake ITA No.208/Coch/2025 as lead case for narration of facts.\nITA No.208/Coch/2025- The assessee filed its return of income for\nAY 2017-18 and the case was selected for complete scrutiny Notices\nunder Sections 143(2

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

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

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

section 14A should be limited to only interest liability and not overheads or administrative expenditure; which should be considered for disallowance under rule 8D from 2007-08 onwards.” The conclusion of the Hon’ble Court was therefore that prior to 2007-08 no overhead or administrative expenditure could be disallowed and only interest expenditure could be disallowed. For AY after

MALANADU MILK PRODUCERS SOCIETY,KOTTAYAM vs. DCIT, EXEMPTION, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

Bench: Shri George George K. & Ms. Padmavathy S.

Section 2(15) will not be applicable in your case and the exemption allowed by Assessing Officer should not be disallowed. ITA NoS.632 & 633/Coch/2022 Page 3 of 12 4. In such circumstances, you are requested to explain why the assessment order passed u/s 143

MALANADU FARMERS SOCIETY ,KOTTAYAM vs. DCIT EXEMPTIONS, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

Bench: Shri George George K. & Ms. Padmavathy S.

Section 2(15) will not be applicable in your case and the exemption allowed by Assessing Officer should not be disallowed. ITA NoS.632 & 633/Coch/2022 Page 3 of 12 4. In such circumstances, you are requested to explain why the assessment order passed u/s 143

M/S THURAYUR SERVICE CO -OP BANK LTD,KOZHIKODE vs. THE ITO WARD 2(1), KOZHIKODE

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

143(3) of the Income Tax Act, 1961 (the Act). Cases called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte. 2. During the course of hearing we find that both the learned lower authorities have disallowed assessee’s section

M/S THURAYUR SERVICE CO -OP BANK LTD,KOZHIKODE vs. THE ITO WARD 2(1), KOZHIKODE

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

143(3) of the Income Tax Act, 1961 (the Act). Cases called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte. 2. During the course of hearing we find that both the learned lower authorities have disallowed assessee’s section

KERALA STATE CO-OPERATIVE BANK LTD,THIRUVANANTHAPURAM vs. DCIT,CIRCLE-1(1), THIRUVANANHAPURAM

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

2) A person shall be considered to have under-reported his income, if— Page 5 of 14 (a) the income assessed is greater than the income determined in the return processed under clause (a) of sub- section (1) of section 143; (b) the income assessed is greater than the maximum amount not chargeable to tax, where no return of income