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

THE KATTOOR SERVICE COOPERATIVE BANK LIMITED,THRISSUR vs. INCOME TAX OFFICER, WARD 2(1), THRISSUR, THRISSUR

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

section\n139(1) of the Income Tax Act, 1961 (the Act) was filed by the\nappellant for AY 2014-15. However, the National Faceless\nAssessment Centre (hereinafter called \"the AO\"), based on the\ninformation that the appellant made cash deposit formed an opinion\nthat income escaped assessment to tax. Accordingly, a notice u/s. 148\nof the Act was issued

THE KATTOOR SERVICE COOPERATIVE BANK LIMITED,THRISSUR vs. INCOME TAX OFFICER, WARD 2(1), THRISSUR, THRISSUR

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

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

section 139(1) of the Income Tax Act, 1961 (the Act) was filed by the appellant for AY 2014-15. However, the National Faceless Assessment Centre (hereinafter called "the AO"), based on the information that the appellant made cash deposit formed an opinion that income escaped assessment to tax. Accordingly, a notice u/s. 148 of the Act was issued

THE KATTOOR SERVICE COOPERATIVE BANK LIMITED,THRISSUR vs. INCOME TAX OFFICER, WARD 2(1), THRISSUR, THRISSUR

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

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

section 139(1) of the Income Tax Act, 1961 (the Act) was filed by the appellant for AY 2014-15. However, the National Faceless Assessment Centre (hereinafter called "the AO"), based on the information that the appellant made cash deposit formed an opinion that income escaped assessment to tax. Accordingly, a notice u/s. 148 of the Act was issued

EDAKKAD URBAN SAHAKARANA SANGAM,KANNUR vs. ITO, WARD-1 & TPS, KANNUR

In the result, the appeal filed by the assessee stands dismissed

Section 148, in response to which the assessee filed a return declaring income of Rs. 15,06,410/-. The AO disallowed

AMBALAPPUZHA SERVICE CO-OPERATIVE SOCIETY LTD,AMBALAPPUZHA vs. ITO, WARD -2, ALAPPUZHA

In the result, the appeal filed by the assessee stands partly allowed the and stay application stands dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm & Sa No. 53/Coch/2025 Assessment Year: 2015-16 Ambalapuzha Service Co-Op. Bank Ltd. .......... Appellant Kakkazham, Vandanam, Alappuzha 688005 [Pan: Aacak0787F] Vs. The Income Tax Officer. Ward-2, Alappuzha .......... Respondent Appellant By: Shri Suresh Kumar Varma, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 30.05.2025 Date Of Pronouncement: 23.06.2025

section 139(1) of the Income Tax Act, 1961 (the Act). The ITO, Ward-2, Alappuzha (hereinafter called "the AO"), based on the information that the appellant made cash deposit of Rs. 58,00,000/- formed an opinion that income escaped assessment to tax. Accordingly, notice u/s. 148 of the Act. In response to the notice the appellant submitted that

KOODARANHI REGIONAL AGRICULTURAL WELFARE CO-OP SOCIETY LTD,KOZHIKKODE vs. THE ITO, KOZHIKKODE

In the result, the appeal by the assessee is allowed for statistical purposes and the stay petition is dismissed

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

disallowance of deduction claimed under any of the provisions of Chapter VI-A under the heading "C.—Deductions in respect of certain incomes" (which includes deduction under section 80P of the Act), can be made if the return is furnished beyond the due date specified under sub-section (1) of section 139. Prior to the amendment the deduction could

M/S.MUKKAM MEGA MULTIPURPOSE CO-OP SOCEITY LTD,KOZHIKKODE vs. THE ITO, KOZHIKKODE

In the result, the appeal by the assessee is allowed for statistical purposes and the stay petition is dismissed

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

disallowance of deduction claimed under any of the provisions of Chapter VI-A under the heading "C.—Deductions in respect of certain incomes" (which includes deduction under section 80P of the Act), can be made if the return is furnished beyond the due date specified under SP No.76/Coch/2022 & ITA No.952/Coch/2022 Page 7 of 9 sub-section (1) of section

KADAVATHUR SERVICE CO-OPERATIV BANK LTD ,KADAVATHUR vs. ACIT, WARD-2, KANNUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

disallowed by the Assessing Officer /CPC on the ground that the assessee has filed the return of income u/s.139(4) of the Act, meaning thereby the 2 ITA No.213/Coch/2024. Kadavathur SCB Limited assessee has filed belated return, and hence, not entitled for the deduction u/s.80P of the Act. 3. Aggrieved with the order of the CPC, the assessee filed

MOOSPET SERVICE CO-OPERATIVE BANK LTD 682 ,THRISSUR vs. INCOME TAX OFFICER WARD 1(1), THRISSUR

In the result, the appeal of the assessee stands dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm Assessment Year: 2018-19 Moospet Service Co-Op. Bank Ltd. .......... Appellant Moospet P.O., Thrissur 680006 [Pan: Aaeam8229N] Vs. The Income Tax Officer, Ward -1(1) .......... Respondent Aayakar Bhavan, Shakthan Thampuran Ngar, Thrissur 680001 Appellant By: ------- None ------- Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 03.02.2025 Date Of Pronouncement: 21.02.2025

disallowed the claim of deduction of Rs. 4,52,13,522/- invoking provisions of section 80AC(ii) and also made addition of Rs. 79,460/- u/s. 36(1) of the Act. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action of the AO. 4. Being aggrieved, assessee is in appeal

EDAMALAYAR SERVICE COOPERATIVE SOCIETY IX 103A,KOTHAMANGALAM vs. ITO, WARD 1 AND TPS , THODUPUZHA, THODUPUZHA

In the result, the appeal filed by the assessee stands dismissed

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

disallowance u/s.80P of the Act by holding that that the appellant did not file the return of income placing reliance on the provisions of section 80A(5) of the Act and also the decision of the Hon’ble jurisdictional High Court in the case of Nileshwar Range Kallu Chethu Vyavasaya Thozhilali Sahakarana Sangham

PANTHEERANKAVE SERVICE CO-OPERATIVE BANK,KOZHIKODE vs. ITO,WARD -2(3), KOZHIKODE

In the result, the appeal filed by the assessee stands dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2017-18 Pantheerankav Service Co-Op. Bank Ltd. .......... Appellant Olavanna, Kozhikode 673019 [Pan: Aaaap6394F] Vs. Income Tax Officer, Ward-2(3), Kozhikode .......... Respondent Appellant By: Shri Arun Raj S., Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 04.06.2025 Date Of Pronouncement: 30.06.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 12.12.2024 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. The Appellant Had Not Filed Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) For Ay 2017-18. Based On The Information That The Appellant Made

disallowances. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order, placing reliance on the decision of the Hon'ble Jurisdictional High Court in the case of Nileshwar Range Kallu Chethu Vyavasaya Thozihilali Sahararana Sangham [2023] 459 ITR 730 (Ker), confirmed the action of the AO. 4. Being aggrieved, the appellant is in appeal

KADUKUTTY SERVICE CO-OPERATIVE BANK LTD - NO: 628,THRISSUR vs. WARD 1, (1), THRISSUR, THRISSUR

In the result, the appeal filed by the assessee stands dismissed

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2013-14 Kadukutty Service Co-Op. Bank Ltd. .......... Appellant Kadukutty P.O., (Via) Chalakkudy, Thrissur [Pan: Aabak0755A] Vs. The Income Tax Officer, Ward-1(1), Thrissur .......... Respondent Assessee By: Shri Yash, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 18.07.2025 For Assessment Year (Ay) 2013-14. 2. Brief Facts Of The Case Are That The Assessee Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant Had Not Filed Return Of Income For Ay 2013-14 Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act). Based On The Information That The Appellant Had Deposited Cash In The Bank

section 139(1) of the Income Tax Act, 1961 (the Act). Based on the information that the appellant had deposited cash in the bank 2 Kadukutty Service Co-op. Bank Ltd. account of Rs. 12,03,000/-, the National Faceless Assessment Centre, Delhi (hereinafter called "the AO") issued a notice u/s. 148 of the Act on 08.05.2020 after taking prior

KOCHIN CO-OPERATIVE SOCIETY LTD.,KOCHI vs. THE INCOME TAX OFFICER,WARD-2(4) &TPS, KOCHI

In the result, the appeal filed by the assessee stands dismissed

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am Assessment Year: 2014-15 Kochin Co-Operative Society Ltd. .......... Appellant Vii/1832, Lalan Road, Mattancherry Kochi 682002 [Pan: Aabak1735C] Vs. The Income Tax Officer .......... Respondent Ward -2(4) & Tps, Kochi Appellant By: Ms. Niveditha K. Kamath, Advocate Respondent By: Shri Sanjit Kumar Das, Cit. Dr & Smt. Leena Lal, Sr. D.R. Date Of Hearing: 01.04.2025 Date Of Pronouncement: 01.04.2025

disallowing the claim for deduction u/s. 80(P) of the Act. 4. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action of the AO. In paragraph 6.4.9 he relied on the judgement of the Hon'ble Kerala High Court in the case of Nileshwar Range Kallu Chethu Vyavasaya Thozihilali Sahararana Sangham

CHERTHALA TALUK AGRICULTURAL CREDIT COOPERATIVE SOCIETY LTD,ALAPPUZHA vs. ITO, WARD 1 AND TPS, ALAPPUZHA, ALLEPPEY

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

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Cherthala Taluk Agricultural Credit .......... Appellant Co-Operative Societ Ltd. Cherthala P.O., Alappuzha 688524 [Pan: Aacac2301H] Vs. The Income Tax Officer .......... Respondent Ward - 1 & Tps, Alappuzha

disallowing the claim for deduction u/s. 80(P) of the Act. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action of the AO. 4. Being aggrieved, assessee is in appeal before this Tribunal in the present appeal. 5. The learned counsel for the assessee submitted that the CBDT Circular 133/6