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

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

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

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

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

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

SIDDHANTH EX - SERVICEMEN SECURITY SERVICES,VASCO vs. DCIT, CPC, BENGALURU

In the result, the appeal of assessee is dismissed

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

disallowance made by the CPC, Bangalore for delay in depositing the said employee’s contribution before due dates concerning the relevant Act. The ld. DR placed on record the decision of Hon’ble Supreme Court in batch of the appeals, lead case being Checkmate Services P. Ltd. in Civil Appeal No. 2833 of 2016 and submitted that the assessee

M/S SANGAM SOUHARD CREDIT SAHAKARI LIMITED,BAGALKOT vs. DCIT, CPC, BANGALORE

Appeals are ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) आयकर अपऩल सं. / Ita No. 001/Pan/2023 निर्धारण वषा / Assessment Year : 2018-19 Shri Bhagyalaxmi Co-Operative Credit Society Ltd., Mallapur, Pg Main Rd., Ghataprabha, Karnataka-591306 Pan: Aaaas5624D . . . . . . . अपीलार्थी / Appellant बिधम / V/S Dy. Commissioner Of Income Tax, Cpc, Bengaluru . . . . . . . प्रत्यर्थी / Respondent & आयकर अपऩल सं. / Ita No. 030/Pan/2023 निर्धारण वषा / Assessment Year : 2018-19 M/S Sangam Souharda Credit Sahakari Ltd., A/P. Galgali, Taluka-Bilgi, Dist.-Bagalkot-587117 Pan: Aaeas3685G . . . . . . . अपीलार्थी / Appellant बिधम / V/S Dy. Commissioner Of Income Tax, Cpc, Bengaluru . . . . . . . प्रत्यर्थी / Respondent द्वधरध / Appearances Assessee By : Mr Sateesh Nadagouda For Ita No. 001& None For Ita No. 030 [‘Ld. Ar’] Revenue By : Mr N. Shrikanth [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 07/08/2023 घोषणा की तारीख / Date Of Pronouncement : 01/09/2023 आदेश / Order Per G. D. Padmahshali, Am; These Two Appeals Of Different Assessee Are Instituted U/S 253(1) Of Income-Tax Act, 1961 [‘The Act’ Hereafter] Against Respective Orders Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Nfac’ Hereafter] For Assessment Year 2018-19 [‘Ay’ Hereinafter].

disallow 80P deduction in summary assessment u/s 143(1) of the Act. ITAT-Panaji Page 3 of 7 ITA No.001 & 030/PUN/2023 AY 2018-19 Belated Return-143(1)(a)(v) 8. Let us deal with issue of eligibility of the claim of deduction u/s 80P of VI-A of the Act first; it goes without saying that, by virtue

SHRI BHAGYALAXMI CO-OPERATIVE CREDIT SOCIETY LIMITED,MALLAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CPC, BANGALURU

Appeals are ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) आयकर अपऩल सं. / Ita No. 001/Pan/2023 निर्धारण वषा / Assessment Year : 2018-19 Shri Bhagyalaxmi Co-Operative Credit Society Ltd., Mallapur, Pg Main Rd., Ghataprabha, Karnataka-591306 Pan: Aaaas5624D . . . . . . . अपीलार्थी / Appellant बिधम / V/S Dy. Commissioner Of Income Tax, Cpc, Bengaluru . . . . . . . प्रत्यर्थी / Respondent & आयकर अपऩल सं. / Ita No. 030/Pan/2023 निर्धारण वषा / Assessment Year : 2018-19 M/S Sangam Souharda Credit Sahakari Ltd., A/P. Galgali, Taluka-Bilgi, Dist.-Bagalkot-587117 Pan: Aaeas3685G . . . . . . . अपीलार्थी / Appellant बिधम / V/S Dy. Commissioner Of Income Tax, Cpc, Bengaluru . . . . . . . प्रत्यर्थी / Respondent द्वधरध / Appearances Assessee By : Mr Sateesh Nadagouda For Ita No. 001& None For Ita No. 030 [‘Ld. Ar’] Revenue By : Mr N. Shrikanth [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 07/08/2023 घोषणा की तारीख / Date Of Pronouncement : 01/09/2023 आदेश / Order Per G. D. Padmahshali, Am; These Two Appeals Of Different Assessee Are Instituted U/S 253(1) Of Income-Tax Act, 1961 [‘The Act’ Hereafter] Against Respective Orders Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Nfac’ Hereafter] For Assessment Year 2018-19 [‘Ay’ Hereinafter].

disallow 80P deduction in summary assessment u/s 143(1) of the Act. ITAT-Panaji Page 3 of 7 ITA No.001 & 030/PUN/2023 AY 2018-19 Belated Return-143(1)(a)(v) 8. Let us deal with issue of eligibility of the claim of deduction u/s 80P of VI-A of the Act first; it goes without saying that, by virtue

MAGSONS SUPERCENTRE,PANAJI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CPC, BENGALURU (JURISDICTIONAL AO: CIRCLE - 1(1), PANAJI

The appeal of the assessee is DISMISSED

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपीलसं. / Ita No. 14/Pan/2021 धििाारण वर्ा / Assessment Year : 2018-19 Magsons Supercentre, 707, Dayanand Bandodkar Marg, Miramar, Panaji Goa – 403001. . . . . . . . अपीलाथी / Appellant Pan: Aacfm4886A बिाम / Vs Deputy Commissioner Of Income Tax Officer . . . . . . .प्रत्यथी / Respondent Cpc, Bengaluru.

24,009/- on account of delayed payment of employees’ contribution towards PF & ESI. 3.2 Aggrieved by the aforestated additions u/s 36(1)(va) of the Act, assessee carried the disallowance before first appellate authority and in the event of unsuccessful attempt, the assessees brought up the matter in appeal before the Tribunal against said disallowance alleging the action of both

SURAJDATTA SAGUN MORAJKAR,NERUL vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PANAJI GOA, PANAJI

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 122/Pan/2024 Assessment Year : 2017-18 Surajdatta Sagun Morajkar C/O. Sun Estate Developers, Next To Sal De Goa, Bhatti Waddo, Bardez, Goa-403114 Pan : Aempm7614J . . . . . . . Appellant

section 5A of the Act was for the year under consideration engaged in the business of real estate development and construction in the name & style of ‘Sun Estate Developer’ and also a partner in M/s ‘SM Venture.’ The assessee filed his return of income on 30/03/2018 declaring total income at ₹4,47,72,090/- which was subjected to scrutiny

ZUARI MANAGEMENT SERVICES LTD.,GOA vs. DEPUTY COMMISIONER OF INCOME-TAX, CIRCLE - 1, MARGAO

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2009-10 M/S Zuari Management Services Ltd. (Erstwhile Zuari Infrastructure & Developers Ltd., Formerly Zuari Sez Ltd.) Jai Kisaan Nagar, Zuari Nagar, Goa. Pan: Aaacz2903Q . . . . . . . Appellant V/S Dy. Commissioner Of Income Tax, Circle-1, Margao, Goa. . . . . . . . Respondent Represented Assessee By: Mr Salil Kapoor [‘Ld. Ar’] Revenue By: Mr Senthil Kumar N [‘Ld. Dr’] Date Of Conclusive Hearing : 29/01/2026 Date Of Pronouncement : 06/02/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income-

section 35D of the Act was allowed for the said AY. 3. That, in view of the facts and circumstances of the case, the A.O. has erred on facts and in law in disallowing the interest expenditure amounting to Rs. 3,56,51,678/-u/s 36(1)(iii) r.w.s. 37(1) of the Act, without appreciating that the same

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

section 80P(2)(a)(i) of the Act. The CBDT CIRCULAR No.18/2015 F.No.279/Misc./140/2015/ITJ dated 02.11.2015 on the issue of interest SLR securities of banks states that – Page 24 of 36 Akshaya Co-Op credit society Limited & others. 1. “It has been brought to the notice of the Board that in the case of Banks, field officers are taking

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

section 80P(2)(a)(i) of the Act. The CBDT CIRCULAR No.18/2015 F.No.279/Misc./140/2015/ITJ dated 02.11.2015 on the issue of interest SLR securities of banks states that – Page 24 of 36 Akshaya Co-Op credit society Limited & others. 1. “It has been brought to the notice of the Board that in the case of Banks, field officers are taking

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

section 80P(2)(a)(i) of the Act. The CBDT CIRCULAR No.18/2015 F.No.279/Misc./140/2015/ITJ dated 02.11.2015 on the issue of interest SLR securities of banks states that – Page 24 of 36 Akshaya Co-Op credit society Limited & others. 1. “It has been brought to the notice of the Board that in the case of Banks, field officers are taking

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

section 80P(2)(a)(i) of the Act. The CBDT CIRCULAR No.18/2015 F.No.279/Misc./140/2015/ITJ dated 02.11.2015 on the issue of interest SLR securities of banks states that – Page 24 of 36 Akshaya Co-Op credit society Limited & others. 1. “It has been brought to the notice of the Board that in the case of Banks, field officers are taking

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

section 80P(2)(a)(i) of the Act. The CBDT CIRCULAR No.18/2015 F.No.279/Misc./140/2015/ITJ dated 02.11.2015 on the issue of interest SLR securities of banks states that – Page 24 of 36 Akshaya Co-Op credit society Limited & others. 1. “It has been brought to the notice of the Board that in the case of Banks, field officers are taking