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

M/S.SAHYADRI AGENCIES LTD,KANDNASSERY, THRISSUR vs. THE ITO, WD-1(3), THRISSUR

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

56(2)(viib) and section 68 of the I.T.Act in respect of the issue / allotment of shares (OPCCPS). The 13 M/s.Sahyadri Agencies Limited. Assessing Officer ought to have, even in a limited scrutiny assessment, prima facie examined whether there is a case of escapement of income exceeding the amount prescribed under the Board Instructions. The A.O. after prima facie examination

M/S.POPULAR FINANCE,PATHANAMTHITTA vs. THE ACIT, CIRCLE-1, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

iii) any other expenditure (not being in the nature of capital expenditure) laid out or expended wholly and exclusively for the purpose of making or earning such income; (iv) in the case of income of the nature referred to in clause (viii) of sub- section (2) of section 56. a deduction of a sum equal to fifty per cent

M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

iii) any other expenditure (not being in the nature of capital expenditure) laid out or expended wholly and exclusively for the purpose of making or earning such income; (iv) in the case of income of the nature referred to in clause (viii) of sub- section (2) of section 56. a deduction of a sum equal to fifty per cent

M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

iii) any other expenditure (not being in the nature of capital expenditure) laid out or expended wholly and exclusively for the purpose of making or earning such income; (iv) in the case of income of the nature referred to in clause (viii) of sub- section (2) of section 56. a deduction of a sum equal to fifty per cent

M/S CHIRAYINKEEZHU SERVICE CO-OPERATIVE BANK,CHIRAYINKEEZHU vs. ITO, WARD-2(5), TRIVANDRUM

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowed the assessee’s section 80P(2) deduction claim representing its income derived from M/s. Trivandrum District Co-operative Bank Ltd., amounting to Rs. Rs.12,75,20,483/-. The Revenue further seeks to fortify the same on the ground that this assessee is in fact a co-operative bank as per the decision of the hon'ble jurisdictional high court

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

2)(iii) of the 1962 Rules. The first disallowance being made by AO was with respect to the disallowance of proportionate interest expenses in relation to earning of an exempt income , to the tune of Rs.1,56,91,283/-, by invoking provisions of Section

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

2)(iii) of the 1962 Rules. The first disallowance being made by AO was with respect to the disallowance of proportionate interest expenses in relation to earning of an exempt income , to the tune of Rs.1,56,91,283/-, by invoking provisions of Section

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

2)(iii) of the 1962 Rules. The first disallowance being made by AO was with respect to the disallowance of proportionate interest expenses in relation to earning of an exempt income , to the tune of Rs.1,56,91,283/-, by invoking provisions of Section

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

2)(iii) of the 1962 Rules. The first disallowance being made by AO was with respect to the disallowance of proportionate interest expenses in relation to earning of an exempt income , to the tune of Rs.1,56,91,283/-, by invoking provisions of Section

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

2)(iii) of the 1962 Rules. The first disallowance being made by AO was with respect to the disallowance of proportionate interest expenses in relation to earning of an exempt income , to the tune of Rs.1,56,91,283/-, by invoking provisions of Section

CLAPPANA SERVICE CO-OPERATIVE BANK ALTD.,KARUNAGAPPALLY vs. ITO, WARD 1&TPS, ALAPPUZHA

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 Singhassessment Year: 2017-2018 M/S. Clappana Service Co-Operative The Income Tax Officer Bank Limited No.867 V. Ward 1, Alappuzha. Cp/Viii/410 & 411, Clappana Po Karunagappally, Kollam – 690 525 Pan : Aabac2747A. (Appellant) (Respondent) Appellant By : Shri Rajakannan, Advocate Respondent By : Smt. V. Swarnalatha, Sr. D.R. Date Of Pronouncement : 25.09.2024 Date Of Hearing : 12.08.2024 O R D E R Per Bench : This Assessee’S Appeal For A.Y. 2017-18 Arises Against The National Faceless Appeal Centre, Delhi [Cit(A)]’S Din & Order No. Itba/ Nfac/S/250/2023-24/1055921666(1) Dated 11.09.2023, Passed U/S. 250 Of The Income Tax Act, 1961 (The Act).

disallowed the assessee’s section 80P(2) deduction claim representing its income derived from a district co-operative bank amounting to Rs.57,15,277/-. The Revenue further seeks to fortify the same on the ground that this assessee is in fact a co-operative bank as per 2 Clappana SCB Ltd. the decision of the hon'ble jurisdictional high court

M/S.PUTHIYANGADI SERVICE CO-OP BANK,CALICUT vs. THE ITO WARD 1(3), CALICUT

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 Singhassessment Year: 2017-18 M/S. Puthiyangadi Service Co- The Income Tax Officer Operative Bank Limited No.F1421 V. Ward 1(3), Alappuzha. Puthiyangadi Kozhikode – 673 021 Pan : Aacap0749C. (Appellant) (Respondent)

disallowed the assessee’s section 80P(2) deduction claim representing its income derived from the Kozhikode District Co-operative Bank amounting to Rs.43,81,435/-. The Revenue 2 Puthiyangadi SCB Ltd. further seeks to fortify the same on the ground that this assessee is in fact a co-operative bank as per the decision of the hon'ble jurisdictional high

KARASSERY SERVICE CO-OP BANK LTD,MUKKAM vs. THE ITO WARD 2(3), KOZHIKODE

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowed the assessee’s section 80P(2) deduction claims representing its income derived from a district co- operative bank amounting to Rs.52,86,755/-, Rs.2,86,60,990/- and 2,48,98,062/-; respectively, as the case may be. The Revenue supports to fortify the same on the ground that this assessee, in fact, is a co-operative bank

KARASSERY SERVICE CO-OP BANK LTD,MUKKAM vs. THE ITO WARD 2(3), KOZHIKODE

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowed the assessee’s section 80P(2) deduction claims representing its income derived from a district co- operative bank amounting to Rs.52,86,755/-, Rs.2,86,60,990/- and 2,48,98,062/-; respectively, as the case may be. The Revenue supports to fortify the same on the ground that this assessee, in fact, is a co-operative bank

KARASSERY SERVICE CO-OP BANK LTD,MUKKAM vs. THE ITO WARD 2(3), KOZHIKODE

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

disallowed the assessee’s section 80P(2) deduction claims representing its income derived from a district co- operative bank amounting to Rs.52,86,755/-, Rs.2,86,60,990/- and 2,48,98,062/-; respectively, as the case may be. The Revenue supports to fortify the same on the ground that this assessee, in fact, is a co-operative bank

THE ACIT, THIRUVALLA vs. M/S.MUTHOOT PROPERTIES & INVESTMENTS, KOZHENCHERRY

In the result, the appeals of the Revenue are partly allowed for statistical

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

iii) any other expenditure (not being in the nature of capital expenditure) laid out or expended wholly and exclusively for the purpose of making or earning such income; (iv) in the case of income of the nature referred to in clause (viii) of sub-section (2) of section 56. a deduction of a sum equal to fifty per cent

DCIT, THIRUVALLA vs. MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE, KOZHENCHERRY

In the result, the appeals of the Revenue are partly allowed for statistical

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

iii) any other expenditure (not being in the nature of capital expenditure) laid out or expended wholly and exclusively for the purpose of making or earning such income; (iv) in the case of income of the nature referred to in clause (viii) of sub-section (2) of section 56. a deduction of a sum equal to fifty per cent