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

1)(vii) inserted by the Finance Act. 2010 got the assent of the President on 08/05/2010 and hence not applicable for the assessment year under appeal. 5. The Ld. CIT(A) erred in upholding the addition made by the AO towards contribution of Rs.20,00,000/- given to a school for construction of building by holding that

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

1)(vii) inserted by the Finance Act. 2010 got the assent of the President on 08/05/2010 and hence not applicable for the assessment year under appeal. 5. The Ld. CIT(A) erred in upholding the addition made by the AO towards contribution of Rs.20,00,000/- given to a school for construction of building by holding that

VIRUPAXAPPA SIDRAMAPPA BEMBALGI,BELAGAVI vs. INCOME TAX OFFICER, BELGAVU

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 011/Pan/2025 Assessment Year : 2017-18 M/S Virupakaxappa Sidramappa Bembalgi 580, Saraf Katta, Shahapur, Belgaum-590003. Pan : Aadfv3936F . . . . . . . Appellant

41,526/- from which the appellant earned a gross profit of ₹54,63,881/- & net profit of ₹7,65,092/-. For purpose said trading business, the assessee maintained regular books of account as prescribed u/s 44AA of the Act and subjected them to audit u/s 44AB of the Act. With the former details the appellant filed NIL return of income

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

41,079/- u/s 14A of the Act being income from business or u/s 14A of the Act being income from business or profession for the impugned assessment year. profession for the impugned assessment year. 3.1. The ld. Pr. CIT found the assessment order passed under section 143(3) dt. The ld. Pr. CIT found the assessment order passed under section

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

In the result, both appeals of the assessee are allowed

1). If a provision of a statute is unconditionally omitted without a saving clause in favour of pending proceedings, all actions must stop where the omission finds them, and if final relief has not been granted before the omission goes into effect, it cannot be granted afterwards. Savings of the nature contained in section 6 or in special Acts

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

In the result, both appeals of the assessee are allowed

1). If a provision of a statute is unconditionally omitted without a saving clause in favour of pending proceedings, all actions must stop where the omission finds them, and if final relief has not been granted before the omission goes into effect, it cannot be granted afterwards. Savings of the nature contained in section 6 or in special Acts

M/S KAMAT REAL ESTATE DEVELOPERS,,PANAJI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PANAJI., PANAJI

In the result, appeal of the Assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

disallowance of interest of Rs.15,68,152/-, examined original assessment records only and no fresh material had come in his possession after completion of original assessment u/s 143(3) of I.T. Act. 6 ITA.No.336/PAN./2018 M/s. Kamat Real Estate Developers, Panaji, Goa. 5. In the facts and circumstances of the case the Commissioner of Income Tax (Appeals) erred

INFRASTRUCTURE LOGISTICS PVT. LTD.,DONA PAULA vs. JOINT COMM. OF INCOME TAX, RANGE - 1, PANAJI

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 380/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 Infrastructure Logistics Pvt. Ltd. Cidade De Goa, Vainguinim Beach, Dona Paula, Goa-403 004. Pan : Aaaci9107R .......अपीलाथ" / Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Range-1, Panaji-Goa, ……""यथ" / Respondent आयकर अपील सं. / Ita No. 381/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 The Assistant Commissioner Of Income Tax, Central Circle, Panaji-Goa, .......अपीलाथ" / Appellant बनाम / V/S.

c) Without prejudice to the ground numbers 2(a) & (b), the CIT(A) in not allowing the alternative ground of the appellant that the average of the value of investments which yielded exempted income alone is to be considered for calculating disallowance as per rule 8D(2)(iii) and not on the basis of the average of total value

ASSTT. COMM. OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. INFRASTRUCTURE LOGISTICS PVT. LTD., DONA PAULA

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 380/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 Infrastructure Logistics Pvt. Ltd. Cidade De Goa, Vainguinim Beach, Dona Paula, Goa-403 004. Pan : Aaaci9107R .......अपीलाथ" / Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Range-1, Panaji-Goa, ……""यथ" / Respondent आयकर अपील सं. / Ita No. 381/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 The Assistant Commissioner Of Income Tax, Central Circle, Panaji-Goa, .......अपीलाथ" / Appellant बनाम / V/S.

c) Without prejudice to the ground numbers 2(a) & (b), the CIT(A) in not allowing the alternative ground of the appellant that the average of the value of investments which yielded exempted income alone is to be considered for calculating disallowance as per rule 8D(2)(iii) and not on the basis of the average of total value

BARDC BANK,BHATKAL vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the two appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.296 & 297/Pan/2024 (A.Y. 2017-18 & 2018-19) Bardc Bank Bhatkal, Ito-Ward-1, Vs Pld Bank, Main Road, Santerikrupa, . Uttara Kannada, Kaigaroad, Bhatkal S.O. Habbuwada, Karnataka-581320. Karwar-581306, Karnataka. Pan .No. Aaaap1731G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

41,16,360/- and passed the order u/sec 143(3) of the Act dated 10.12.2019. 4. Aggrieved by the order, the assessee has filed an appeal before the CIT(A), whereas the CIT(A) has considered the grounds of appeal, submissions of the assessee and findings of the A.O but sustained the denial of claim of deduction of interest income

BARDC BANK,BHATKAL vs. INCOME TAX OFFICER, WARD - 1, KARWAR

In the result, the two appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.296 & 297/Pan/2024 (A.Y. 2017-18 & 2018-19) Bardc Bank Bhatkal, Ito-Ward-1, Vs Pld Bank, Main Road, Santerikrupa, . Uttara Kannada, Kaigaroad, Bhatkal S.O. Habbuwada, Karnataka-581320. Karwar-581306, Karnataka. Pan .No. Aaaap1731G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

41,16,360/- and passed the order u/sec 143(3) of the Act dated 10.12.2019. 4. Aggrieved by the order, the assessee has filed an appeal before the CIT(A), whereas the CIT(A) has considered the grounds of appeal, submissions of the assessee and findings of the A.O but sustained the denial of claim of deduction of interest income

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

1 lakh or more and thirdly, by laws of the co-operative society do not permit admission of any other co- operative society as a member, it would be regarded to be primary co- operative bank. According to the AO, the primary object and principal business of the assessee was transaction of banking business. Hence, AO concluded that the appellant

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

1 lakh or more and thirdly, by laws of the co-operative society do not permit admission of any other co- operative society as a member, it would be regarded to be primary co- operative bank. According to the AO, the primary object and principal business of the assessee was transaction of banking business. Hence, AO concluded that the appellant

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

1 lakh or more and thirdly, by laws of the co-operative society do not permit admission of any other co- operative society as a member, it would be regarded to be primary co- operative bank. According to the AO, the primary object and principal business of the assessee was transaction of banking business. Hence, AO concluded that the appellant

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

1 lakh or more and thirdly, by laws of the co-operative society do not permit admission of any other co- operative society as a member, it would be regarded to be primary co- operative bank. According to the AO, the primary object and principal business of the assessee was transaction of banking business. Hence, AO concluded that the appellant

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

1 lakh or more and thirdly, by laws of the co-operative society do not permit admission of any other co- operative society as a member, it would be regarded to be primary co- operative bank. According to the AO, the primary object and principal business of the assessee was transaction of banking business. Hence, AO concluded that the appellant

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

1 lakh or more and thirdly, by laws of the co-operative society do not permit admission of any other co- operative society as a member, it would be regarded to be primary co- operative bank. According to the AO, the primary object and principal business of the assessee was transaction of banking business. Hence, AO concluded that the appellant

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

1 lakh or more and thirdly, by laws of the co-operative society do not permit admission of any other co- operative society as a member, it would be regarded to be primary co- operative bank. According to the AO, the primary object and principal business of the assessee was transaction of banking business. Hence, AO concluded that the appellant

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

1 lakh or more and thirdly, by laws of the co-operative society do not permit admission of any other co- operative society as a member, it would be regarded to be primary co- operative bank. According to the AO, the primary object and principal business of the assessee was transaction of banking business. Hence, AO concluded that the appellant