INCOME TAX OFFICER-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD., MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowances were made in respect to certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was allowed. It is settled law that if a query is raised during the allowed. It is settled law that if a query is raised

ITO-26(2)(1) , MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowances were made in respect to certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was allowed. It is settled law that if a query is raised during the allowed. It is settled law that if a query is raised

ITO-26(2)(1), MUMBAI vs. SAI PRERANA CO-OP CREDIT SOCIETY LTD, MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowances were made in respect to certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was allowed. It is settled law that if a query is raised during the allowed. It is settled law that if a query is raised

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowances were made in respect to certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was allowed. It is settled law that if a query is raised during the allowed. It is settled law that if a query is raised

SAI PRERNA CO-OP. CREDIT SOCIETY LTD,MUMBAI vs. ITO WD 17(3) (2) , MUMBAI

In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are In the result, appeals of the assessee and the Revenue are decided as under:

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Ita Nos. 217, 220 & 221, 218 & 219, 215, 214/Mum/2023 Assessment Years: 2013-14, 2016-17, 2017-18, 2018-19, 2020-21 Sai Prerana Co-Op Credit Ito-17(3)(2), Society Ltd., Room No. 126, 1St Floor, Vs. 317, Puran Aasha Bldg, Gr. Fl. Kautilya Bhavan, C-41 To C- Narashi Natha Street, Katha 43, G Block Bandra Kurla Bazar Masjid Bunder (W), Complex, Bandra (East), Mumbai-400 009. Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent

disallowances were made in respect to certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was certain items, the claim of deduction under Section 80P was allowed. It is settled law that if a query is raised during the allowed. It is settled law that if a query is raised

INCOME TAX OFFICER , MUMBAI vs. IDBI STAFF CO-OPERATIVE CREDIT SOCIETY LTD , MUMBAI

In the result, all the appeals in ITA Nos

disallowed the deduction, which was confirmed by the CIT(A). The Revenue preferred an appeal before the Tribunal.", "held": "The Tribunal held that interest income earned by a co-operative society from its investments with other co-operative banks is eligible for deduction under Section 80P(2)(d) of the Act. The exclusion under Section 80P(4) does not apply

RUSTOMJEE ASPIREE PREMISES CO-OP SOC. LTD ,MUMBAI vs. ITO, WARD 26(2)(5), MUMBAI

In the result the appeal filed by the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Rustomjee Aspiree Premises Co- Ito Ward 26(2)(5), Op. Soc. Ltd., Room No. 319, 3Rd Floor, Kautilya Vs. Ground Floor, Rustomjee Bhavan, C-41 To C-43, ‘G’ Block Aspiree, Cts No. 628, Ai, Pt Bandra Kurla Complex, Bandra Kurla, Eatern Express Highway, (East), Mumbai-400051. Sion, Mumbai-400022. Pan No. Aabar 4001 L Appellant Respondent

1. Whether the learned Tribunal was justified in deleting the additions made by the Assessing Authority being the disallowed additions made by the Assessing Authority being the disallowed additions made by the Assessing Authority being the disallowed deduction claimed u/S 80P(2)(d) of the Income Tax Act and in the deduction claimed u/S 80P(2)(d) of the Income

SHRI KUMAR COOPERATIVE HOUSING SOCIETY LTD,MUMBAI vs. JAO MUM -W-22(3)(1), MUMBAI

Appeal of the assessee are allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2021-22 Shrikumar Co-Operative Housing Asst. Dir. Of I. Tax, Cpc Jao Mum- Society Ltd., W-22(3)(1), Vs. Nehru Road, Santacruz (East), Piramal Chamber, Mumbai-400055. Mumbai-400012. Pan No. Aaaas 8110 J Appellant Respondent

disallowed in the above-mentioned order. mentioned order. 5.2. The appellant has claimed deduction under Section 80P. The 5.2. The appellant has claimed deduction under Section 80P. The 5.2. The appellant has claimed deduction under Section 80P. The relevant part of the Act is being reproduced below: relevant part of the Act is being reproduced below: "80P(1

JAI JALARAM CO-OPERATIVE CREDIT SOCIETY LIMITED,MUMBAI vs. THE INCOME TAX OFFICER, WARD 29(1)(5), MUMBAI

In the result appeal of the assessee is allowed partly for esult appeal of the assessee is allowed partly for esult appeal of the assessee is allowed partly for statistical purpose

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-16 Jai Jalaram Co-Operative Credit The Ito Ward 29(1)(5), Society Ltd., Kautilya Bhavan, Bandra Kurla Vs. Shop No. -2 Ground Floor, Shop Complex, No. -2 Ground Floor, Mulund Mumbai-400051. Siddhivinayak C.H.S. Near Punjab National Bank Zaver Road, Mulund West, Mumbai-400080. Pan No. Aaaaj 2603 B Appellant Respondent

disallowed the deduction claimed for the interest earned from Cooperative banks u/s 80P. With regard to the interest or erative banks u/s 80P. With regard to the interest or erative banks u/s 80P. With regard to the interest or dividend income earned from a Co dividend income earned from a Co-operative bank/ Scheduled operative bank/ Scheduled Bank

JCIT (OSD), CC-4(4), MUMBAI vs. M/S. SHRI RENUKAMATA MULTI-STATE COOPERATIVE URBAN CREDIT SOCIETY LTD., AHAMEDNAGAR

1,39,81,267 is bad in law and ought to be\ndeleted.\n8. Disallowance of deduction under section 80P

GOLD COIN APARTMENTS CO OPERATIVE HOUSING SOCIETY LTD ,MUMBAI vs. ITO WARD 22(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

80P by inserting a new sub Section (4) so as to provide that the provisions of the said section shall not apply in relation to any co-operative bank other than primary co-operative and rural development bank. 3. The learned Asstt. Director of Income Tax CPC Bengaluru CPC vide intimation u/s.143(1) dated 30.09.2022 has erred is disallowing

SANGAM SAHAKARI PATPEDHI MARYADITNAGARI,NAVI MUMBAI, THANE vs. MUMBAI-W-91, VASHI NAVIMUMBAI

In the result, both the appeal of the assessee are allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16 & Assessment Year: 2020-21 Sangam Sahakari Patpedhi Mumbai-W-91, Maryaditnagari, Navi Mumbai, It-Office, Vashi Railway Station Office No. 227, Central Facility Vs. Building Navi Mumbai-400703. Building, 3Rd Floor, Sector-19, Turbhe, Navi Mumbai-400705. Pan No. Aacas 6296 B Appellant Respondent

1-4-2007. The AO has taken a view that pursuant The AO has taken a view that pursuant to insertion of s to insertion of sub-section (4) of section 80P, the appellant would no more section (4) of section 80P, the appellant would no more be entitled for claim of deduction under section 80P

SHRI RENUKAMATA MULTI-STATE CO-OPERATIVE URBAN SOCIETY LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 4(4), MUMBAI

1,39,81,267 is bad in law and ought to be\ndeleted.\n8. Disallowance of deduction under section 80P

M/S RENUKAMATA MULTI STATE CO-OP. URBAN CREDITN SOC. LTD.,MUMBAI vs. THE ASSTT. CIT, CC-4(4), MUMBAI

In the result, the appeal by the assessee is partly allowed, while the\nappeal by the Revenue is dismissed

1,39,81,267 is bad in law and ought to be\ndeleted.\n8. Disallowance of deduction under section 80P

INCOME TAX OFFICER, BKC,MUMBAI vs. IDBI STAFF CO-OPERATIVE SOCIETY LTD, MUMBAI

disallowed this deduction by invoking Section 80P(4). The CIT(A) overturned the AO's decision. The Revenue appealed this order.", "held": "The Tribunal held that interest income earned by a co-operative society from its investments with other co-operative banks is eligible for deduction under Section 80P(2)(d) of the Income-tax Act. Section 80P(4) does

PARSI SALSETTE BLDG NO. 1 CHS LIMITED ,MUMBAI vs. INCOME TAX OFFICER 24(3)(1), MUMBAI

Accordingly, Ground No. II raised by the Assessee is allowed and as a result, Ground No

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

disallowance made fell outside the scope of adjustments specified in Section 143(1) of the Act and (b) in Ground No. II that even on merits the Assessee was entitled to claim deduction under Section 80P

M/S RENUKAMATA MULTI STATE CO-OP. URBAN CREDITN SOC. LTD.,MUMBAI vs. THE ASSTT. CIT, CC-4(4), MUMBAI

1,39,81,267 is bad in law and ought to be\ndeleted.\n\n8. Disallowance of deduction under section 80P

SADHANA SAHAKARI PATPEDHI LIMITED,VASAI, PALGHAR vs. CIT(A), NFAC , DELHI

Sections 143(3A) & 143(3B) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’]. 3. The Appellant has raised following grounds of appeal: “1. The Hon'ble CIT-(A), NFAC has aggrieved your appellant by confirming the additions made by the learned A.O. for Rs.2,46,43,418/- by disallowing deduction claimed u/s 80P