M/S VEEJAY FACILITY MANAGEMENT PVT. LTD,PANAJI vs. DCIT, CPC, BANGALORE

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri G.D. Padmahshali

disallowance of expenditure or increase in income indicated in the audit report but not taken into account in computing the total income in the return’ 8. Sub-section (1) of section 143 states that a return shall be processed to compute total income by making six types of `adjustments’ as set out in sub-clauses (i) to (vi). As noted

ACIT, CENTRAL CIRCLE, PANAJI vs. M/S SOCIADADE DE FOMENTO INDUSTRIAL P. LTD, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

24 ITA.No.105 & 116/PAN./2018 Sociedade De Fomento Industrial Pvt. Ltd., Margao, Goa. from the average investment and to re-work the disallowance under section

SOCIEADADE DE FOMENTO INDL. PVT. LTD.,MARGAO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

24 ITA.No.105 & 116/PAN./2018 Sociedade De Fomento Industrial Pvt. Ltd., Margao, Goa. from the average investment and to re-work the disallowance under section

GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE INCOME TAX OFFICER, WARD - 1(1), PANAJI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.344/Pan/2017 (A.Y.2013-14 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Sesa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent

24) of the 1961, Act is the inclusive definition including specifically 'dividend' and that "section 115-O pertain to declaration, distribution or payment of dividend by company and imposition of additional tax on dividend is thus clearly covered by subject as embraced by Entry 82 ". Once the Hon'ble Supreme Court has held that dividend connotes ' income ', the natural corollary

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2 (1), PANAJI., PANAJI vs. SHREE KALIKA URBAN CO-OP. CREDIT SOCIETY LIMITED , MAPUSA

In the result, the appeal filed by the Revenue stands dismissed

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.367/Pan/2017 िनधा"रण वष" / Assessment Year : 2014-15 Acit, Circle-2(1), .......अपीलाथ" / Appellant Panaji. बनाम / V/S. Shree Kalika Urban Co-Op. Credit Society Ltd., Block No.6, Om Chambers, Feira Baiya, Near Laxminarayan Temple, Mapusa Bardes, Goa. ……""यथ" / Respondent Pan : Aacas1697Q Revenue By : Shri Sourabh Nayak Assessee By : Shri R. K. Pikale सुनवाई क" तारीख / Date Of Hearing : 09.11.2021 घोषणा क" तारीख / Date Of Pronouncement : 15.11.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Revenue Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Panaji (‘Cit(A)’ For Short) Dated 20.09.2017 For The Assessment Year 2014-15. 2. The Revenue Raised The Following Grounds Of Appeal :- “1. The Order Of The Ld. Cit (A) Is Opposed To Law & Facts Of The Case. 2. The Ld. Cit(A) Has Erred In Deleting Addition On Account Of Disallowance Of Deduction In Respect Of Income Of Co-Operative Society U/S. 80P(2)(A)(I), 80P(2)(C)(Ii), 80P(2)(D) & 40(A)(Ia) On The Ground That The Assessee Is A Co- Operative Society, Accepts Deposits Only From Its Members & Can Lend Money Only To Its Members & It Cannot Issue Cheque Books, When The Assessee Accepts Deposits & Grants Loans To Its Members On Which It Makes Profit & Gain By Way Of Charging Interest, Thus Providing Credit Facility Is Akin To Banking Business As Per Section 2(24)(Viia) & Part-V Of The Banking Regulation Act, 1949, Hence The Assessee Is Not Eligible For Deduction U/S. 80P.

24)(viia) of I. T. Act 1961 and also fulfills all three requirements as given in section 5(ccv) of the Banking Regulation Act, 1949 to qualify as Primary Co-operative Bank. 4. Appellant craves leave to amend or alter any of the grounds of appeal or add to the same, if deemed necessary.” 3. Briefly, the facts

PRIYADARSHANI MAHILA CO-OP CR. SOCIETY LTD,BELAGAVI vs. DCIT, CPC, BANGALORE

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 032/Pan/2025 Assessment Year : 2019-20 Priyadarshani Mahila Co-Op. Society Ltd. At Post: Kognoli, Ta.: Nippani Dist. Belagavi. Pan : Aabap2582L . . . . . . . Appellant

24 of ITAT- Rules, 1963. Recording the same advanced accordingly. 3. Tersely stated facts of the case are that; 3.1 The assessee is a co-operative society and for the year under consideration filed its return of income u/s 139(4) of the Act on 23/09/2029 declaring total income at NIL after claiming deduction u/s 80P of chapter

SHREE AMBEY FORGING PRIVAT LIMITED,PANAJI vs. ITO, WARD - (4), PANAJI

In the result, both appeals of the assessee are allowed

disallowance on such deduction. Hence, it cannot be held that Assessing Officer has not conducted any enquiry or investigated the issue which he was required to do so before allowing the claim of deduction u/s 80 IA or has allowed without examining the assessee's transaction with its subsidiary, Noida Towers Private Limited. 24. One of the key allegations

SCORPIO IRON LTD,PANAJI vs. ITO, WARD - 1(4), PANAJI

In the result, both appeals of the assessee are allowed

disallowance on such deduction. Hence, it cannot be held that Assessing Officer has not conducted any enquiry or investigated the issue which he was required to do so before allowing the claim of deduction u/s 80 IA or has allowed without examining the assessee's transaction with its subsidiary, Noida Towers Private Limited. 24. One of the key allegations

INCOME TAX OFFICER, WARD -2(2), , BELGAVI vs. SHIVA CREDIT SOUHARDA SAHAKARI NIYAMIT, BELGAVI

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

24) (viia) by the Finance Act, 2006 with effect from 01.04.2007, includes the profit and gains of any business of banking (including providing credit facilities) carried on by a co-op society with its members. The A.O. further held that deduction under section 80P shall not be available to a Co-operative Bank other than a Primary Agricultural Credit Society

SHRI ANANTANATH ALPASANKHYATAR VIVIDH UDDESHAGAL SOUHARD SAHAKARI SANGH NIY,BELAGAVI vs. INCOME TAX OFFICER, NFAC, DELHI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 006/Pan/2025 Assessment Year : 2009-10 Shri Anantanath Alpasankhyatar Vivid Uddheshagal Souhardha Sahakari Sangh Niyamit [‘Saavusssn’] 1738, Anantnath Building, Jain Galli, Main Rd., Kannur Niyamit Kalloli, Kalloli, Belagavi. Pan : Aagts1962B . . . . . . . Appellant V/S Income Tax Office, Ward-1, Gokak, Belagavi. . . . . . . . Respondent Appearances Assessee By : Mr Sachin Nichal [‘Ld. Ar’] Revenue By : Mr Deshmukh Prakash [‘Ld. Dr’] Date Of Conclusive Hearing : 02/06/2025 Date Of Pronouncement : 03/06/2025 Order Per G. D. Padmahshali; This Appeal Is Filed Against Din & Order 1070608483(1) Dt. 25/11/2024 Passed By The National Faceless Appeal Centre, Delhi [‘Ld. Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Arisen Out Of Order Of Penalty Dt. 23/03/2022 Passed U/S 271(1)(C) Of The Act By The National Faceless Assessment Centre Delhi [‘Ld. Nfeac’ Hereinafter] Anent To Assessment Year 2009-10 [‘Ay’ Hereinafter].

24)(via) of the Act, and thus assessed the total income at ₹10,15,647/-. Further by such order the Ld. AO also initiated a penalty proceedings u/s 271(1)(c) r.w.s. 274 of the Act for furnishing inaccurate particulars. When the penalty show cause & other notices remained unattended, the Ld. NFeAC by an order dt. 23/03/2022, culminated the penalty

SHRI NITIN A SHIRGURKAR,BELGAVI vs. PR. CIT, HUBBALI

In the result, the appeal of the assessee is allowe

Bench: Dr. M. L. Meena & Shri Anikesh Banerjee

disallow a sum of Rs.30,086/- i.e. 1,00,288 X 30%= Rs.30,086/ i.e. 1,00,288 X 30%= Rs.30,086/- as per provisions of Section 40(a)(ia) of the Act, which has not been provisions of Section 40(a)(ia) of the Act, which has not been done. 3. On perusal of records, the following observations have

M/S. AHILIABAI SARDESSAI, ,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1), PANAJI

In the result, appeal of assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2015-16 M/S. Ahiliabai Sardessai Assistant Commissioner Of 301, Lotus Court, M. G. Income-Tax, Circle-1(1), Vs. Road, St. Inwz Junction, Panaji. Panaji, Goa-403001. (Pan: Aagfa9044G) (Appellant) (Respondent) Present For: Appellant By : Shri N. J. Prabhudesai, Ar Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 17.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A), Panaji-1 Vide Ita No. Cit(A), Pnj-1/10391/2017-18 Dated 14.09.2018 For A.Y. 2015-16 Passed Against The Assessment Order U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit, Circle-1(1), Panaji, Goa Dated 13.12.2017. 2. Shri N. J. Prabhudesai, Ar Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Appeared On Behalf Of The Revenue.

24,911/- u/s. 14A read with Rule 8D of the Rules. Aggrieved, the assessee went in appeal before the Ld. CIT(A) who deleted the disallowance of Rs.2,01,472/- in respect of disallowance under rule 8D(2)(i) and restricted the disallowance under Rule 8D(2)(ii) to Rs.1,216/-. However, Ld. CIT(A) confirmed the addition of rs.5

VEERENDRA BASAVARAJ KOUJALAGI,BELAGAVI vs. PCIT HUBBALLI, HUBBALLI

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 103/Pan/2024 Assessment Year : 2018-19 Veerendra Basavaraj Koujalagi C/O. Shri Laxmi Complex, Sadashiv Nagar, Belgavi-590001 Pan : Agrpk3086D . . . . . . . Appellant V/S The Pr. Commissioner Of Income Tax, Hubali. . . . . . . . Respondent Appearances Assessee By : Mr Shivanand Halbhavi [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 24/06/2025 Date Of Pronouncement : 28/07/2025 Order Per G. D. Padmahshali; The Assessee’S Captioned Appeal Impugns Din & Order 1063626985(1) Dt. 29/03/2024 Passed By Pr. Commissioner Of Income Tax, Hubali [‘Ld. Pcit’] U/S 263 Of The Income-Tax Act, 1961 [‘The Act’] Which Sought To Revise Order Of Assessment Dt. 26/04/2021 Passed U/S 143(3) R.W.S. 144B Of The Act By National Faceless E-Asstt. Centre, Delhi [‘Ld. Ao’] Anent To Assessment Year 2018-19 [‘Ay’].

disallowance of expenditure in earning such exempt income in terms of section 14A of the Act r.w.r 8D of IT-Rules, 1962, in the light of former judicial precedents (supra), the action of Ld. PCIT in holding the order of assessment as erroneous & prejudicial to the interest of revenue is very well sustainable in law. Ergo we find no infirmity

THE MARKANDEY MAHILA MULTIPURPOSE CO-OP. SOCIETY LTD,BELGAUM vs. ITO, WARD - 1(2), BELGAUM

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 372/Pan/2017 "नधा"रण वष" / Assessment Year : 2012-13 The Markendey Mahila Multipurpose Co-Op Society Ltd.,12, At Post-Kangrail-Khurd, Taluka & Dist. Belgaum. Pan : Aabam5563C .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward -1(2), Belgaum ……""यथ" / Respondent Assessee By : Shri Pramod Vaidhya, Ar Revenue By : Shri Sourabh Nayak, Sr. Dr

disallowing deduction u/s.80P(2)(d). 2. The learned CIT(A) erred in not appreciating that for the purpose of section 80P(2)(d) a Co-operative bank should be considered as a Co- operative society. 3. Without prejudice to above, the learned CIT(A) erred in not appreciating that the assessee was in the business of providing credit facilities

SHRI GOPALKRISHNA CO-OPERATIVE SOCIETY LIMITED,BHATKAL vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Bench: Hon’Ble Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Asstt Sr

disallowance, we deem it necessary to reiterate certain key factual matrix of the case here viz; (1) the appellant is a registered society under State Co-op Societies Act (2) the appellant is a Co-operative Society within the meaning of section 2(19) of the Act (3) the appellant is engaged in providing credit facilities to its member

SHRI GOPALKRISHNA CO-OPERATIVE SOCIETY LIMITED,BHATKAL vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Bench: Hon’Ble Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Asstt Sr

disallowance, we deem it necessary to reiterate certain key factual matrix of the case here viz; (1) the appellant is a registered society under State Co-op Societies Act (2) the appellant is a Co-operative Society within the meaning of section 2(19) of the Act (3) the appellant is engaged in providing credit facilities to its member

THE MARCEL URBAN CO-OPERATIVE CREDIT SOCIETY LIMITED,MARCEL vs. INCOME TAX OFFICER, WARD - 2(3), PANAJI

Bench: Hon’Ble Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Asstt Sr

disallowance, we deem it necessary to reiterate certain key factual matrix of the case here viz; (1) the appellant is a registered society under State Co-op Societies Act (2) the appellant is a Co-operative Society within the meaning of section 2(19) of the Act (3) the appellant is engaged in providing credit facilities to its member

PRATHAMIK KRUSHI PATTIN SAHAKARI SANGH NIYAMIT,BEDKIHAL vs. INCOME TAX OFFICER, WARD - 1, NIPANI

Bench: Hon’Ble Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Asstt Sr

disallowance, we deem it necessary to reiterate certain key factual matrix of the case here viz; (1) the appellant is a registered society under State Co-op Societies Act (2) the appellant is a Co-operative Society within the meaning of section 2(19) of the Act (3) the appellant is engaged in providing credit facilities to its member

HEBBAL URBAN CREDIT SOUHARDA SAHAKARI NIYAMIT.,BELAGAVI vs. THE INCOME TAX OFFICER WARD-1, GOKAK

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

Bench: Shri Partha Sarathi Chaudhury, Jm

disallowance of the deduction claimed u/s 80P(2)(a)(i) of the Act of Rs. 6,94,510/- on the ground that, the appellant is not co-operative society as per provisions of section 80P(2)(a)(i) of the Act. 5. The ld. CIT(A) failed to appreciate that, as per section 2€ of Karnataka Souharda Sahakari