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

68,38,319 54,12,931 80P(2)(a)(i) Tax demand if deduction u/s 80P(2)(a)(i) is restricted to income earned from 80,77,256 76,45,770 84,00,520 members only Alternate claim of deduction considering deduction under section

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

68,38,319 54,12,931 80P(2)(a)(i) Tax demand if deduction u/s 80P(2)(a)(i) is restricted to income earned from 80,77,256 76,45,770 84,00,520 members only Alternate claim of deduction considering deduction under section

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

2)/2Q13-14/453 dated ' 25.02.2014" (Emphasis added) 6.8 Further, in the said reasons, at various places reference was given of the February 2014. This goes to prove that the survey report was received by the AO in the month of February 2014 only. 6.9 In view of the above, the Appellant submits that since the survey report had been received

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

section 80P(2)(a)(i) deduction of Rs.1,03,68,974/-; representing it’s interest received from fixed deposit

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

section 80P(2)(a)(i) deduction of Rs.1,03,68,974/-; representing it’s interest received from fixed deposit

SAHAKARI GANNA VIKAS SAMITI,UTTAR PRADESH vs. ITO-2(5) CHANDAUSI, UTTAR PRADESH

In the result, appeal of the assessee is allowed

Bench: Sh. Kul Bharat & Sh. Pradip Kumar Kediasahakari Ganna Vikas Vs. Ito-2(5), Samiti, Sikri Gate Chandausi Chandausi, Sambhal, Uttar Pradesh Uttar Pradesh-244 412 Pan No. Aaaaf 1459 L (Appellant) (Respondent) Assessee By Shri Fuzail Ahmad Ayyubi, Adv. Revenue By Shri Anuj Garg, Sr. D.R. Date Of Hearing: 19.07.2023 Date Of Pronouncement: 19.07.2023

2,22,704/- under section 80P of the Act. The issue for consideration before us is that whether once the return of income is filed beyond the prescribed date under section 139(1) of the Act, can the deduction under section 80P of the Act be denied to the assessee, by way of adjustment under section

CA COOPERATIVE THRIFT & CREDIT SOCIETY LTD,DELHI vs. PCIT, DELHI

In the result the appeal of the assessee in ITA Nos

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

2,87,90,915/- in A.Y 2015-16 after making addition u/s 68 of the Act. 5. Assuming jurisdiction conferred upon him by provisions of section 263 of the Act, the PCIT issued a show cause notice holding that the assessment order dated 24.12.2019 is not only erroneous but also prejudicial to the interest of the revenue

CA COOPERATIVE THRIFT & CREDIT SOCIETY LIMITED ,DELHI vs. PCIT, DELHI-20, DELHI

In the result the appeal of the assessee in ITA Nos

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

2,87,90,915/- in A.Y 2015-16 after making addition u/s 68 of the Act. 5. Assuming jurisdiction conferred upon him by provisions of section 263 of the Act, the PCIT issued a show cause notice holding that the assessment order dated 24.12.2019 is not only erroneous but also prejudicial to the interest of the revenue

THE GENERAL MANAGER,NAJIBABAD vs. ACIT, NAJIBABAD

In the result, the appeal of the assessee is allowed for statistical

Bench: the due date of filing the return.

80P(2)(d) of the Act for Rs.10,00,000/- and restricted the claim of deduction only to Rs.2,94,68,223/- (3,04,68,223-10,00,000). The Ld. CIT(A) upheld the action of the AO. 6. At the outset, we find that the assessee had given loans to three Co-operative Societies and earned interest income

DCIT, NAJIBABAD vs. M/S KISAN SAHKARI CHINNI MILLS LTD., NAJIBABAD

In the result, the appeal of the assessee is allowed for statistical

Bench: the due date of filing the return.

80P(2)(d) of the Act for Rs.10,00,000/- and restricted the claim of deduction only to Rs.2,94,68,223/- (3,04,68,223-10,00,000). The Ld. CIT(A) upheld the action of the AO. 6. At the outset, we find that the assessee had given loans to three Co-operative Societies and earned interest income

DISTRICT CO- OPERATIVE BANK LTD.,DEHRADUN vs. DCIT, DEHRADUN

In the result appeal of the assessee is allowed

Bench: Sh. A.T.Varkey, Jm & Sh. Prashant Maharishi, Am Ita No. 3533/Del/2012 : Asstt. Year : 2007-08

68,580/- on 24.11.2009. 03. While passing assessment order AO initiated penalty proceedings u/s 271(1) (c) of the act. In response to the penalty notice assessee submitted before AO that :- a. The Deduction was available to the assessee up to A Y 2006-07 and therefore this year assessee was under impression about the availability of this deduction

M/S. M.NAGAR DISTT. CO-OP DEVELOPMENT FED. LTD.,MUZAFFARNAGAR vs. JCIT, MUZAFFARNAGAR

Bench: Shri R.S. Syal & Smt Suchitra Kamble

68,467.74 The net profit of Rs.6,16,467,74/- so derived above was claimed to be exempted u/s 80P(2) (i)(a). It was noticed by the A.O that the profit is mainly due to interest and head office (Fertilizers sale transportation storage). The A.O also gathered on examining the two accounts that income from transportation at Rs.5

MUZAFFARNAGAR DISTT. COOPERATIVE DEVELOPMENT FEDERATION LTD.,MUZAFFARNAGAR vs. ACIT, MUZAFFARNAGAR

Bench: Shri R.S. Syal & Smt Suchitra Kamble

68,467.74 The net profit of Rs.6,16,467,74/- so derived above was claimed to be exempted u/s 80P(2) (i)(a). It was noticed by the A.O that the profit is mainly due to interest and head office (Fertilizers sale transportation storage). The A.O also gathered on examining the two accounts that income from transportation at Rs.5

M/S MUZAFFARNAGAR DISTT. CO-OPERATIVE DEVELOPMENT FEDERATION LTD.,UTTAR PRADESH vs. ADDL. CIT, MUZAFFARNAGAR

Bench: Shri R.S. Syal & Smt Suchitra Kamble

68,467.74 The net profit of Rs.6,16,467,74/- so derived above was claimed to be exempted u/s 80P(2) (i)(a). It was noticed by the A.O that the profit is mainly due to interest and head office (Fertilizers sale transportation storage). The A.O also gathered on examining the two accounts that income from transportation at Rs.5

M/S MUZAFFARNAGAR DISTT. CO-OPERATIVE DEVELOPMENT FEDERATION LTD.,UTTAR PRADESH vs. ADDL. CIT, MUZAFFARNAGAR

Bench: Shri R.S. Syal & Smt Suchitra Kamble

68,467.74 The net profit of Rs.6,16,467,74/- so derived above was claimed to be exempted u/s 80P(2) (i)(a). It was noticed by the A.O that the profit is mainly due to interest and head office (Fertilizers sale transportation storage). The A.O also gathered on examining the two accounts that income from transportation at Rs.5

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

68,020/- which was subsequently revised declaring total income of Rs. 1,21,16,08,860/-. Return of income was initially processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) and was later selected for scrutiny under CASS. The assessment was completed at an income of Rs. 1,36,67,12,228/- after, inter alia

ALLIED FINANCE P. LTD.,NEW DELHI vs. ACIT, DELHI

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2015-16 Co-Operative Cane Vs. Income Tax Officer, Development Union Ltd., Ward-1(2), Cane Union, Hapur, Ghaziabad Uttar Pradesh Pan: Aaajc0224M (Appellant) (Respondent) With Assessment Year: 2010-11 With Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2011-12 With Assessment Year: 2012-13 With Assessment Year: 2012-13

section 80P deduction going by Totgars Co-operative Sale Society Ltd. Vs. ITO, Karnataka [2010] 188 Taxman 282 (SC). 5. Learned departmental representative accordingly reiterates before us that all these three heads of the assessee’s receipts could be held to have been derived from the eligible undertaking and business activities; as the case may be, which has been

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)

2. of the Master Circular No. RBI/2011-12/107dated 1 July 2011 (enclosed at Page45-67 of Paperbook – A)which mandatorily requires the banks to invest in PTCs issued by the securitization trust. The investment made by the assessee in PTCs issued by “Sansar Trust 2012” also qualifies as investment as per the Master Circular No. RBI/2011-12/107dated 1 July 2011 as certified

ACIT, MEERUT vs. M/S. SARVA UP GRAMIN BANK, MEERUT

In the result, the appeal of the Revenue is dismissed

Bench: Sh. Bhavnesh Saini & Dr. B. R. R. Kumar

80P" The object of the substitution, as explained in para 5 of the CBDT Circular No. 464, dt. 18th July, 1986, was to give the separate deduction, viz., one in respect of rural advances and the other for provision for bad and doubtful debts in general and also to extend the benefit of deduction to all banks including foreign banks