THE MANTOLA COOPERATIVE THRIFT & CREDIT SOCIETY,NEW DELHI vs. ITO WARD-62(5), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 4078/Del/2019 : Asstt. Year : 2012-13 Ita No. 6935/Del/2018 : Asstt. Year : 2013-14 Ita No. 2036/Del/2019 : Asstt. Year : 2014-15 The Mantola Cooperative Vs Income Tax Officer, Thrift & Credit Society Ltd., Ward-62(5), 541, Mantola, Phar Ganj, New Delhi New Delhi-110055 (Appellant) (Respondent) Pan No. Aaajt1976A Assessee By : Sh. Gaurav Jain, Adv. Revenue By : Ms. Rakhi Vimal, Sr. Dr Date Of Hearing: 22.06.2020 Date Of Pronouncement: 27.07.2020

E-Court Module) ITA No. 4078/Del/2019 : Asstt. Year : 2012-13 ITA No. 6935/Del/2018 : Asstt. Year : 2013-14 ITA No. 2036/Del/2019 : Asstt. Year : 2014-15 The Mantola Cooperative Vs Income Tax Officer, Thrift & Credit Society Ltd., Ward-62(5), 541, Mantola, Phar Ganj, New Delhi New Delhi-110055 (APPELLANT) (RESPONDENT) PAN No. AAAJT1976A Assessee by : Sh. Gaurav Jain, Adv. Revenue

THE MANTOLA COOPERATIVE THRIFT & CREDIT SOCIETY LTD,NEW DELHI vs. ITO, WARD-62(5), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 4078/Del/2019 : Asstt. Year : 2012-13 Ita No. 6935/Del/2018 : Asstt. Year : 2013-14 Ita No. 2036/Del/2019 : Asstt. Year : 2014-15 The Mantola Cooperative Vs Income Tax Officer, Thrift & Credit Society Ltd., Ward-62(5), 541, Mantola, Phar Ganj, New Delhi New Delhi-110055 (Appellant) (Respondent) Pan No. Aaajt1976A Assessee By : Sh. Gaurav Jain, Adv. Revenue By : Ms. Rakhi Vimal, Sr. Dr Date Of Hearing: 22.06.2020 Date Of Pronouncement: 27.07.2020

E-Court Module) ITA No. 4078/Del/2019 : Asstt. Year : 2012-13 ITA No. 6935/Del/2018 : Asstt. Year : 2013-14 ITA No. 2036/Del/2019 : Asstt. Year : 2014-15 The Mantola Cooperative Vs Income Tax Officer, Thrift & Credit Society Ltd., Ward-62(5), 541, Mantola, Phar Ganj, New Delhi New Delhi-110055 (APPELLANT) (RESPONDENT) PAN No. AAAJT1976A Assessee by : Sh. Gaurav Jain, Adv. Revenue

ITO, WARD- 63(5), NEW DELHI vs. THE JWALA COOPERATIVE URBAN THRIFT AND CREDIT SOCIETY LTD., NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 5623/Del/2018 : Asstt. Year : 2012-13 Income Tax Officer, Vs The Jwala Cooperative Urban Ward-63(5), Thrift & Credit Society Ltd., New Delhi-110002 218, Dda Cycle Market, Jhandewalan Extn. New Delhi-110055 (Appellant) (Respondent) Pan No. Aabat0924C Assessee By : Ms. Gunjan Jain, Ca Revenue By : Sh. Ratan Singh, Sr. Dr Date Of Hearing: 20.10.2021 Date Of Pronouncement: 20.01.2022

E” : DELHI BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER ITA.No.2900 & 2901/Del./2015 Assessment Years 2010-2011 & 2011-2012 The Jawala Cooperative Urban Thrift & Credit Society Limited, 218-219, Cycle Market, Jhandewalan Extn. New Delhi – The ACIT, Circle-62(1) 110 055. vs Civic Centre, PAN AABAT0924C New Delhi – 110 002. (Appellant) (Respondent) Shri Puneet

THE MANTOLA COOPERATIVE THRIFT & CREDIT SOCIETY LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result the appeals filed by the assessee stands partly allowed

Bench: Shri S. V. Mehrotra & Smt. Beena A. Pillai

disallowance the Ld. AO did not consider the fact that bank interest also include interest earned on deposit with other co- operative banks. 12 I.T.A.Nos.483-487/Del/2013 I.T.A.Nos.2828,2829/Del/2015 I.T.A.No. 177/Del/2014 4.3 He thus concluded by submitting that the assessee is eligible for deduction of entire interest earned under section 80P(2)(d). 5. On the contrary

THE JANTA ADARSH CO-OPERATIVE THRIFT & CREDIT SOCIETY LTD.,DELHI vs. ITO WARD-52(1), DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Kul Bharat

section 2(19) of the Act. 5. That, without prejudice to ground No. 1 to 3, on the facts and in the circumstances of the case the case the Ld. CIT(A), NFAC has grossly erred both on facts and in law in confirming the addition Rs.7,60,197/- by not allowing deduction u/s.80P(2

JANTA ADARSH CO-OPERATIVE THRIFT & CREDIT SOCIETY LTD.,NEW DELHI vs. ITO,WARD-52(1), NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Kul Bharat

section 2(19) of the Act. 5. That, without prejudice to ground No. 1 to 3, on the facts and in the circumstances of the case the case the Ld. CIT(A), NFAC has grossly erred both on facts and in law in confirming the addition Rs.7,60,197/- by not allowing deduction u/s.80P(2

MUZAFFARNAGAR DISTRICT COOPERATIVE BANK LTD.,MUZAFFARNAGAR vs. DCIT, CIRCLE- 1 , MUZAFFARNAGAR

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: Sh. Satbeer Singh Godara & Sh. M. Balaganeshita No. 1708/Del/2018 : Asstt. Year : 2015-16 Muzaffarnagar District Cooperative Vs Dcit, Bank Ltd., C/O Anil Deep & Company, Circle-1, 41/85, Sadar Bazar, Muzaffarnagar, Muzaffarnagar Uttar Pradesh-251001 (Appellant) (Respondent) Pan No. Aaaam4327P Assessee By : Sh. Sanjay Malik, Adv. Revenue By : Sh. Akhilesh Kumar Yadav, Sr. Dr Date Of Hearing: 02.12.2024 Date Of Pronouncement: 05.12.2024 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2015-16, Arises Against The Order Of Cit(A), Muzaffarnagar Dated 16.01.2018 In Case No. 9258-7434-250-717, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

E’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member & Sh. M. Balaganesh, Accountant Member ITA No. 1708/Del/2018 : Asstt. Year : 2015-16 Muzaffarnagar District Cooperative Vs DCIT, Bank Ltd., C/o Anil Deep and Company, Circle-1, 41/85, Sadar Bazar, Muzaffarnagar, Muzaffarnagar Uttar Pradesh-251001 (APPELLANT) (RESPONDENT) PAN No. AAAAM4327P Assessee by : Sh. Sanjay Malik, Adv. Revenue by : Sh. Akhilesh Kumar

MUFG BANK LTD,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION) CIRCLE-2(2)(1), NEW DELHI

In the result appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)

e. Disallowance made under Rule – 8D(2)(ii) is bad as the assessee had enough interest free funds available. Each of the aforesaid contention is explained in detail below. Section 14A is not applicable in case of bank when the investments are held as stock-in-trade: It is submitted that the investment in PTCs is made by the assessee

SAINI CO-OPERATIVE THARIFT AND CREDIT SOCIETY LTD,DELHI vs. ITO WARD-48(1), DELHI

In the result, the appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

e In D I N & o rde r N o. Thr ift an d ITB A /NF AC/ S /25 0 /20 24 - C red it So c ie t y 25 /1 067 76 652 3 (1 ) Da te d: Lt d. 20. 08 .2 024 2. Heard both the parties at length. Case files perused. Saini Co-operative

SAINI CO-OPERATIVE THARIFT AND CREDIT SOCIETY LTD,DELHI vs. ITO WARD-48(1), DELHI

In the result, the appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

e In D I N & o rde r N o. Thr ift an d ITB A /NF AC/ S /25 0 /20 24 - C red it So c ie t y 25 /1 067 76 652 3 (1 ) Da te d: Lt d. 20. 08 .2 024 2. Heard both the parties at length. Case files perused. Saini Co-operative

CIT vs. KRIBHCO

80P(2)(d) of the Act and, therefore, has to be disallowed under Section 14A. 5. The assessee succeeded in the first appeal and before the tribunal. We may notice that in the first appeal, the assessee had raised several contentions on merits as to the quantum of disallowance of the expenditure under the head “interest” and had pointed

COMMISSIONER OF INCOME TAX

80P(2)(d) of the Act and, therefore, has to be disallowed under Section 14A. 5. The assessee succeeded in the first appeal and before the tribunal. We may notice that in the first appeal, the assessee had raised several contentions on merits as to the quantum of disallowance of the expenditure under the head “interest” and had pointed

ITO, WARD-58(7), NEW DELHI vs. THE CO-OPERATIVE URBAN THRIFT & CREDIT SOCIETY LTD, DELHI

In the result, the appeal is partly allowed

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2018-19 Ito, Ward-58(7), The Co-Operative Urban Thrift New Delhi & Credit Society Ltd., 31/64, Vs. Bhikam Singh Colony, (Pan:Aabat2253J) Vishwas Nagar, Shahdara Delhi-1100 32

E R PER SAKTIJIT DEY, VICE PRESIDENT: This is an appeal by the Revenue against order dated 31.05.2022 passed by National Faceless Appeal Centre (NFAC), Delhi for the assessment year 2018-19. 2. The present appeal raises two issues. The first issue is with regard to availability of deduction under Section 80P(2)(d)-(i) of the Income

INCOME TAX OFFICER, WARD-1(2)(4), MEERUT vs. MALIYANA COOPERATIVE CANE DEVELOPEMENT UNION, GORAKHPUR

Appeal is dismissed

Bench: Ms. Madhumita Roy & Shri Naveen Chandraasstt. Yr: 2018-19

e-Assessment Centre, Delhi under Section 143(3) r.w.s. 143(3A) & 143(3B) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for Assessment Year 2018-19. Grounds of appeal taken by the Revenue read as under: 2 “1. That the CIT(A), NFAC has erred in law and in facts by not appreciating the disallowance

ITO, WARD-63(5), NEW DELHI vs. THE JAWALA CO-OPERATIVE URBAN THRIFT AND CREDIT SOCIETY LTD, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year : 2014-15 Ito, Ward-63(5), Vs. The Jawala Co-Operative New Delhi. Urban Thrift & Credit Society Ltd. 218, Dda Comml Complex, Cycle Market, Jhandewalan Extn., New Delhi – 110 055 Pan Aabat0824C (Appellant) (Respondent)

e-filed its return of income declaring income of Rs. 1,42,020/- after claiming deduction of Rs. 58,23,657/- under section 80P of the Income Tax Act, 1961 (“Act”). The return was processed under section 143(1) of the Act. Subsequently, the case was selected for scrutiny under CASS and assessment under section 143(3) was framed

M/S. RELIGARE SECURITIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the assessee stands allowed in terms of our directions contained in the preceding

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastavaasstt. Year: 2008-09

2)(iii) of I.T. Rules . 6. Thus, in light of above, Central Board of Direct Taxes, in exercise of its powers under section 119 of the Act hereby clarifies that Rule 8D read with section 14A of the Act provides 24 M/s. Religare Securities Ltd. vs ACIT for disallowance of the expenditure even where taxpayer in a particular year

THE MANTOLA COOPERATIVE THRIFT & CREDIT SOCIETY,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Kuldip Singh & Shri Anadee Nath Misshra

E R PER BENCH : 2 ITA Nos.2830 to 2834/Del./2015 Since common questions of facts and law have been raised in all the aforesaid appeals, the same are being disposed off by way of composite order to avoid repetition of discussion. 2. Appellant, The Mantola Cooperative Thrift & Credit Society, (hereinafter referred to as ‘the assessee’), by filing the present appeal

THE MANTOLA COOPERATIVE THRIFT & CREDIT SOCIETY,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Kuldip Singh & Shri Anadee Nath Misshra

E R PER BENCH : 2 ITA Nos.2830 to 2834/Del./2015 Since common questions of facts and law have been raised in all the aforesaid appeals, the same are being disposed off by way of composite order to avoid repetition of discussion. 2. Appellant, The Mantola Cooperative Thrift & Credit Society, (hereinafter referred to as ‘the assessee’), by filing the present appeal

THE MANTOLA COOPERATIVE THRIFT & CREDIT SOCIETY,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Kuldip Singh & Shri Anadee Nath Misshra

E R PER BENCH : 2 ITA Nos.2830 to 2834/Del./2015 Since common questions of facts and law have been raised in all the aforesaid appeals, the same are being disposed off by way of composite order to avoid repetition of discussion. 2. Appellant, The Mantola Cooperative Thrift & Credit Society, (hereinafter referred to as ‘the assessee’), by filing the present appeal