M/S R. S. SHETYE & BROS,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), PANAJI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.37/Pan/2023 (A.Y.2016-17) R.S.Shetye & Bros, Vs Acit 1(1), Flat.No.14, 1 St Floor, Aaykar Bhavan, . Trionara Apartments, Edc, Patto, New Muncipal Market, Panjim Panaji- Goa-403001. Goa-403001. Pan .No.Aabfr9785N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

gains and such expenditure incurred for acquiring such lease hold right including expenditure towards renewal of mining lease is a capital expenditure. The A.O find that the stamp duty paid for the renewal of mining lease is towards the execution of the lease deed is a capital expenditure being the acquisition of capital asset u/sec2

MAHENDRA PURUSHOTTAM NAIK GAUNEKAR,PANAJI vs. INCOME TAX OFFICER, PANAJI

Accordingly. The ground thus stands allowed

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20,64,75,000) sold by appellant during the year Instead of actual sale consideration of Rs. 11,30,04,244 (50 percent of Rs. 22,70,08,408) received on sale of said lands for the purpose of recomputing the capital gains (Long Term) in his assessment order passed for the year and in adding the difference

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PATTO PLAZA vs. ESTEEM INDUSTRIES PRIVATE LIMITED, PLOT

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshali

capital expenditure of ₹1,94,57,703/- relating to technical know-how. Aggrieved by the first addition, the assessee filed an appeal which the Ld. NFAC allowed by reversing the alleged addition. Aggrieved thereby the Revenue came in this second appeal seeking to overturn former deletion. ITAT-Panaji Page 3 of 20 DCIT Vs Esteem Industries Pvt. Ltd. ITA Nos.253/PAN/2024

M/S SOVA,PANAJI vs. PR. COMMISSIONER OF INCOME TAX, PANAJI

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2018-19 M/S Sova Salgaocar Bhavan, Altinho, Panaji, Goa-403001. Pan: Aacfs8862Q . . . . . . . Appellant V/S Pr. Commissioner Of Income Tax, Panaji, Goa. . . . . . . . Respondent

gain of business ITAT-Panaji Page 2 of 20 M/s Sova Vs PCIT ITA No. 024/PAN/2024 AY: 2018-19 profession [‘PGBP’] were disallowed and (ii) receipt/credit representing (a) reimbursement of extraction cost incurred ₹4,42,48,443/-, (b) credit balances written off ₹14,03,127/-, (c) interest on bank deposits ₹16,39,202/- & (d) interest on tax-refund

SHREE MAHILA CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,BELAGAVI vs. ITO WARD 1 BELAGAVI, BELAGAVI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.116/Pan/2024 (A.Y. 2017-18) Shree Mahila Credit Souhard Vs Ito-Ward-2, Sahakari Sangh Niyamit, Feroj Khimjibhai Cpx, . Shop.No.3, Maruti Complex, Civil Hospital Road 2 Nd Railway Gate, Tilakwadi, Belagavi-590001. Belgaum-500006, Karnataka. Karnataka. . Pan .No. Aabas9244A (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Pramod Y Vaidya.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.02.2026 घोषणा की तारीख/Date Of Pronouncement 13.02.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of The Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Partially Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Act Made By The Assessing Officer & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act & Sustaining Denial Of Deduction Of Interest On Income Tax Refund Under Section 80P(2)(A)(I) Of The Act.

20(2)(2). Mumbai (ITA No. 6139/Mum/2014, dated 27.09.2017. (iv). Kaliandas Udyog 9 ITA. No..116/PAN/2024 Shree Mahila Credit Souhard Sahakari Sangh Niyamit.. Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars

GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANAJI., SELECT CITY

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak Ripote

20, vs. Tax, Panaji, Aayakar EDC Complex, Patto, Panaji, Bhavan, Plot No.5, EDC Goa – 403 001 Complex, Patto Plaza, PAN AAACG4447J Panaji, Goa – 403 001. (Appellant) (Respondent) For Assessee : Shri Ketan Ved For Revenue : Shri P.S. Shivshankar, CIT-DR Date of Hearing : 10.10.2023 Date of Pronouncement : 13.10.2023 ORDER PER SATBEER SINGH GODARA, J.M. : This assessee’s appeal for assessment year

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PANAJI, AYAKAR BHAWAN vs. VPK URBAN COOPERATIVE CREDIT SOCIETY , VPK BHAWAN

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

VPK URBAN CO-OPERATIVE CREDIT SOCIETY,MARDOL, PONDA vs. INCOME TAX OFFICER, PANAJI, GOA

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

SHREE BASVANNA MAHADEV CO-OPERATIVE CREDIT SOCIETY LIMITED,BELAGAVI vs. INCOME TAX OFFICER WARD 6, BELGAUM

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

VPK URBAN CO-OPERATIVE CREDIT SOCIETY,MARDOL, PONDA vs. DCIT/ACIT, NEAC, DELHI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

PRATHAMIK KRISHI PATTIN SAHAKARI SANGH NIYAMIT LTD BHOJ,BHOJ vs. INCOME TAX OFFICER, WARD-1, NIPANI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

THE ADARSH MULTIPURPOSE CO-OPERATIVE SOCIETY,BELAGAVI vs. INCOME TAX OFFICER WARD 1-(2) , BELAGAVI, BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

SAMARTH URBAN CO-OPERATIVE CREDIT SOCIETY LTD,BELGAUM vs. PR. COMMISSIONER OF INCOME TAX , BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

VPK URBAN CO-OPERATIVE CREDIT SOCIETY,MARDOL, PONDA vs. INCOME TAX OFFICER, PANAJI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

THE MARATHA URBAN CO-OPERATIVE CREDIT SOCIETY LTD,BELGAUM vs. INCOME TAX OFFICER, WARD - 5, BELGAUM

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

BASAV SOUHARDA CREDIT SAHAKARI NIYAMIT BAILHONGAL,BAILHONGALA vs. INCOME TAX OFFICER NATIONAL E ASSESSMENT CENTER, BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

SHRI BASAVESHWAR URBAN CO OPERATIVE CREDIT SOCIETY LTD,BELAGAVI vs. INCOME TAX OFFICER NATIONAL E ASSESSMENT, BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

SHRI BASAVESHWAR URBAN CO OPERATIVE CREDIT SOCIETY LIMITED,BELAGAVI vs. INCOME TAX OFFICER NATIONAL E ASSESSMENT CENTRE, BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation

KUMTA ADIKE MARATA SOPUHARDA SAHAKARI SANGH NIYAMIT,KUMTA vs. INCOME TAX OFFICER, WARD - 2, KARWAR

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

20 of 36 Akshaya Co-Op credit society Limited & others. recorded in the books of account date wise. The amounts received from members and deposits made are not in contravention to the objectives of demonetization. During the assessment and appellate proceedings various details called for were submitted by the assessee to substantiate cash deposits during demonetization with proper documentation