RESERVE BANK STAFF AND OFFICERS CO-OP CREDIT SOCIETY LTD,MUMBAI vs. ITO WARD 26 (1)(1), MUMBAI

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

Section 80P(2)(a) or 80P(2)(d) of the Income-tax Act, 1961 (the Act) of interest income earned by the assessee from the co- operative banks. All these appeals have identical facts. Therefore, disposed off by this common order. 02. Grounds in ITA No. 3114/Mum/2023 for A.Y. 2013-14:- “1. On facts and in circumstances of the case

RESERVE BANK STAFF AND OFFICERS CO-OP CREDIT SOCIETY LTD,MUMBAI vs. ITO WARD 26 (1)(1), MUMBAI

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

Section 80P(2)(a) or 80P(2)(d) of the Income-tax Act, 1961 (the Act) of interest income earned by the assessee from the co- operative banks. All these appeals have identical facts. Therefore, disposed off by this common order. 02. Grounds in ITA No. 3114/Mum/2023 for A.Y. 2013-14:- “1. On facts and in circumstances of the case

RESERVE BANK STAFF AND OFFICERS CO-OP CREDIT SOCIETY LTD,MUMBAI vs. ITO WARD 26 (1) (1), MUMBAI

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

Section 80P(2)(a) or 80P(2)(d) of the Income-tax Act, 1961 (the Act) of interest income earned by the assessee from the co- operative banks. All these appeals have identical facts. Therefore, disposed off by this common order. 02. Grounds in ITA No. 3114/Mum/2023 for A.Y. 2013-14:- “1. On facts and in circumstances of the case

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

In the result, the appeal of the assessee is partly allowed

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2012-13 Sai Prerana Co-Op Society Ltd., Ito-7(3)(2), 317, Puran Aasha Bldg. Gr. Fl. Room No. 126, 1St Floor, Narashi Natha Street, Katha Vs. Kautilya Bhavan, C-41 To C- Bazar Musjid Bunder (W), 43 Block, Bandra Kurla Mumbai-400 009. Complex, Bandra (East) Mumbai-400051. Pan No. Aadts 5638 M Appellant Respondent Assessee By : Ms. Ruby Srivastava & Mr. Bharat Kumar, Ca Revenue By : Mr. Milind S. Chavan, Dr Date Of Hearing : 27/04/2023 : Date Of Pronouncement 28/04/2023 Order

2 the Supreme Court held: “ The Assessing Offcer has no power to review; he has the The Assessing Offcer has no power to review; he has the The Assessing Offcer has no power to review; he has the power to reassess. But reassessment has to be based on power to reassess. But reassessment has to be based on power

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

reassessment order passed t order passed u/s 147 read with section 143(3) u/s 147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d

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

reassessment order passed t order passed u/s 147 read with section 143(3) u/s 147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d

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

reassessment order passed t order passed u/s 147 read with section 143(3) u/s 147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d

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

reassessment order passed t order passed u/s 147 read with section 143(3) u/s 147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d

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

reassessment order passed t order passed u/s 147 read with section 143(3) u/s 147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d

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

reassessment order passed t order passed u/s 147 read with section 143(3) u/s 147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d

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

reassessment order passed t order passed u/s 147 read with section 143(3) u/s 147 read with section 143(3) of the Act on 03.12.2019 on 03.12.2019, denied the deduction u/s 80P the deduction u/s 80P(2)(d

BHOOMI CLASSIC CO-OP HSG.SOC.LTD.,,MUMBAI vs. ITO WARD-30(1)(2), MUMBAI

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

Bench: Shri Pavan Kumar Gadalebhoomi Classic Co-Op Ito, Ward 30(1)(2) Hsg. Soc. Ltd., Room No. 436, 4Th बनाम/ Cts No. 1406, Link Floor, Kautilya Vs. Road, Opp Sabkuch Bhavan, C-41 To C- Market, Malad (West) 43, G Block, Bkc, Mumbai- 400064. Bandra (E) Mumbai – 400051. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaab4452G (""थ" / Respondent) (अपीलाथ" /Appellant)

reassessment and the Honorable Court has not decided on merit. Hence, the ratio cannot be applicable to the facts of the appellant. Therefore, order of Tribunal for earlier year may be followed and the order of NFAC may be set aside and direction may be given to the Assessing Officer to grant the relief u/s. 80P (2)(d) as claimed

TMT EMPLOYEES CO OPERATIVE CREDIT SOCIETY LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX THANE -1, MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2014-15 Tmt Employees Co-Operative Credit Ito 3(4) Society Ltd., Ashar It Park, 6Th Floor, Road Shop No. 10, Prashaskiya Bhavan, Vs. No. 16Z, Wagle Industrial Thane M P (Tmt) Employees Ccs, Estate, Thane (West)-400604. Wagle Estate Aagar, Thane-400604. Pan No. Aaeat 4545 J Appellant Respondent

Section 80P(2)(d) made in the original reassessment order. As no appeal was filed by the assessee original reassessment

THE PANCHRATNA CO OPERATIVE HOUSING SOCIETY LTD ,MUMBAI vs. INCOME TAX OFFICER -19(3)(1), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

2)(d). The Ld.AR challenged that validity of notice u/s 147 for not found the any tangible material for issuances of notice u/s 148 of the Act. The Ld.AR prayed for quashing the notice u/s 148. 8 The Panchratna Co-operative Housing Society Ltd 7. The Ld. DR argued and submitted that the assessment order was passed ex- parte

JOLLY MAKER 1 PREM CO-OP SOC LTD,MUMBAI CITY vs. ASSISTANT COMMISSIONER OF INCOME TAX 17(2), MUMBAI

In the result, all the appeals of the assessee are allowed for\nstatistical purpose

d) of the Act in respect of interest\nincome from cooperative bank for assessment year 2007-08 to 2010-\n11, 2012-13 and 2018-19.\n13. On the other hand, the 1d. D.R submitted that trust is a legal\nentity different from the assessed cooperative society, therefore, the\nincome earned from the trust cannot be shown in the hands

M/S. DHARAVI SAHAKARI PATPEDHI MARYADIT ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -20 , MUMBAI

In the result appeal filed by the assessee stands dismissed

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

reassessment order on 02/09/2022 under section 143 (3) read with 144B of the act. 3 ITA No.3105/Mum/2025; A.Y. 2020-21 M/s. Dharavi Sahakari Patpedhi Maryadit 4. Subsequently, the Ld.PCIT upon perusing the assessment records observed that, during the assessment proceedings, the assessing officer allowed deduction of Rs. 54,47,586/- under sections 80P of the act, without carrying

TECHNO RESIDENCY CO OPERATIVE HOUSING SOCIETY LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD 20(2)(1), MUMBAI, MUMBAI

Appeal is allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

D E R [ Per Rahul Chaudhary, Judicial Member: 1. The present appeal preferred by the Assessee is directed against the order, dated 17/07/2025, passed by the National Faceless Appeal Centre (NFAC), [hereinafter referred to as ‘the CIT(A)’] whereby the Ld. CIT(A) had dismissed the appeal against the Assessment Order, dated 07/03/2024, passed under Section 147 read with Section

MAHAVIR CO OPERATIVE HOUSING SOCIETY LIMITED ,MUMBAI vs. ITO, WARD, 19(1)(1), MUMBAI

In the result the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

reassessment u/s 147 read with sections 148 and 148A of the 1.T. 2 ITANo.3409/Mum/2024; A.Y. 2016-17 Mahavir Co-operative Housing Society Limited Act, 1961 as the same is barred by limitation provided in section 149 of the I.T. Act, 1961. 2. Assumption of jurisdiction by AO is bad in law as notice u/s 148 is issued after elapse