PRIME MINERAL EXPORTS PRIVATE LIMITED (NOW AMALGAMATED WITH FOMENTO RESOURCES PRIVATE LIMITED),PANAJI vs. JOINT COMMISSIONER OF INCOME TAX, RANGE - 1, PANAJI

The appeal stands partly allowed for statistical purpose in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 003/Pan/2023 Assessment Year : 2009-10 Prime Mineral Exports Pvt. Ltd. (Now Amalgamated With Fomento Resources Pvt. Ltd.) 102, 1St Fl. Kamat Metropolis-1, Behind Caculo Mall, St. Inez, Panaji, Goa-403001. . . . . . . .Appellant Pan : Aadcp1647E V/S Jt. Commissioner Of Income Tax, . . . . . . . Respondent Range-1, Panaji, Goa

3 and ground number 4. ITAT-Panaji Page 4 of 42 Prime Mineral Exports Pvt. Ltd.(Now Amalgamated with Fomento Resources Pvt. Ltd.) Vs JCIT, Panaji ITA Nos.003/PAN/2023 AY: 2009-10 4. We have heard rival party’s submission and subject to rule 18 of ITAT-Rules, 1963 perused material placed on records by the date and considered relevant facts

ACGL BBD EMPLOYEES COOP CREDIT SOCIETY LTD,BHUIMPAL HONDA SATTARI GOA vs. INCOME TAX OFFICER, WARD 1(1), PANAJ, PANAJI, GOA

The appeal of the assessee stands allowed

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 212/Pan/2024 Assessment Year : 2017-18 Acgl Bbd Employees Co-Op. Credit Society, Ltd. Bhuimpal Honda, Sattari, Bhuimpal, North Goa. Pan : Aaaaa8278M . . . . . . . Applicant V/S Income Tax Officer Ward-1(1), Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr S J Kamat [‘Ld. Ar’] Revenue By : Mr Narendra Reddy [‘Ld. Dr’] Date Of Conclusive Hearing : 06/02/2025 Date Of Pronouncement : 12/02/2025 Order Per G. D. Padmahshali, Am; The Assessee Is In Appeal Against Din & Order No. Itba/Nfac/S/250/2024-25/1066146872(1) Dt. 27/06/2024 Passed U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] By The National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)/Nfac’ Hereinafter] Which In Turn Arisen Out Of Order Of Assessment Dt. 19/12/2019 Passed U/S 143(3) Of The Act By The Income Tax Officer, Ward-1(1), Panaji [‘Ld. Ao’ Hereinafter] For Assessment Year 2017-18 [‘Ay’ Hereinafter].

disallowed the deduction holding that the assessee is a cooperative bank and hence not eligible to claim deduction as per Section 80P(4) of the Act. The first and second appellate authority ITAT-Panaji Page 9 of 12 ACGL Employee Co-op.Credit Society Ltd Vs ITO ITA No 212/PAN/2024 AY: 2017-18 and the Hon’ble Jurisdictional High Court held

GOA P W D STAFF CO OP CREDIT SOCIETY LIMITED,PANAJI vs. INCOME TAX OFFICER, WARD-1(1) PANAJI GOA, PANAJI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 107/Pan/2025 Assessment Year : 2017-18 Goa Pwd Staff Co-Operative Credit Society Limited. Pwd New Building, Altinho, Panaji Goa-403 001. Pan : Aabag5329G . . . . . . . Appellant

3 of 9 Goa PWD Staff Co-operative Credit Society Limited Vs ITO, Goa ITA Nos.107/PAN/2025 AY: 2017-18 section 80P(4) shall apply to claimant assessee bank and said provisions shall have no application to the assessee co- operative society which was in receipt of income from the co- operative bank which per-se is a registered society

NAVANIRMAN MULTIPURPOSE CO-OPERATIVE CREDIT SOCIETY LTD,BELAGAVI vs. INCOME TAX OFFICER, WARD - 2, BELAGAVI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 116/Pan/2025 Assessment Year : 2016-17 Navanirman Multipurpose Co-Op. Credit Society Ltd., Laxmi Nagar, Hindalaga, Dist. Belagavi.-591108 Pan : Aacan0420G . . . . . . . Appellant V/S The Income Tax Officer, Ward-2, Belagavi. . . . . . . . Respondent Appearances Assessee By : Mr Pramod Vaidya [‘Ld. Ar’] Revenue By : Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing : 07/08/2025 Date Of Pronouncement : 18/08/2025 Order Per G. D. Padmahshali; By Captioned Appeal The Assessee Impugns Din & Order 1074658686(1) Dt. 18/03/2025 Passed By National Faceless Appeal Centre, Delhi [‘Ld. Nfac/Cit(A)’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Arisen Out Of Order Of Assessment Dt. 15/02/2024 Passed U/S 147 R.W.S. 144 Of The Act By National Faceless E- Asstt Centre, Delhi [‘Ld. Ao’ Hereinafter] Anent To Assessment Year 2016-17 [‘Ay’ Hereinafter].

3. Aggrieved by denial of deduction the assessee unsuccessfully contested the dispute in first appeal before the Ld. NFAC/CIT(A). Dissatisfied by the actions of tax authorities below the assessee instituted the present appeal with substantive grounds which collectively are directed against the denial of deduction u/s 80P(2) of the Act. 4. The Ld. Senior AR Mr Vaidya before

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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

SHRI JAI JINENDRA CREDIT SOUHARDA SAHAKARI LIMITED,BELAGAVI vs. INCOME TAX OFFICER WARD 1 NIPANI, 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 (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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 (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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 (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

SHRI JAI JINENDRA SOUHARDA SAHAKARI SANGH NIYAMIT,BELAGAVI vs. 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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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 (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

VIVIDODDSHESHA PRATHAMIK GRAMEEN KRUSHI SAHAKARI SANGH NIYAMIT SOUDATTI,SOUDATTI vs. INCOME TAX OFFICER WARD-4, BELGAUM, 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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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

section (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale

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 (4) of Sec. 80P was that the co-operative banks which were functioning at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale