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

disallowance of deduction claimed under sections 10AA, 80-IA, 80-IAB, 80-IB, 80-IC, 80-ID or section 80

PARKKOT MARITIME AGENCIES PRIVATE LIMITED.,GOA vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

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

Bench: Shri Laliet Kumar, Jm & Dr. Mitha Lal Meena, Am

disallowance of claim made by the appellant under Section 80- IA. 2) While confirming the disallowance made by the Assistant

PARKKOT MARITIME AGENCIES PRIVATE LIMITED.,GOA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2, MARGAO., MARGAO

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

Bench: Shri Laliet Kumar, Jm & Dr. Mitha Lal Meena, Am

disallowance of claim made by the appellant under Section 80- IA. 2) While confirming the disallowance made by the Assistant

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

In the result, both appeals of the assessee are allowed

section 80 IA with Ministry of Commerce and Industry; and under the Industrial Park Scheme 2002, it was duly notified that industrial park developed by the assessee was eligible 100% exemption u/s 80 IA. It was never in dispute any of the major conditions laid down under the notification issued by the Government of India was ever violated. Such proposed

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

In the result, both appeals of the assessee are allowed

section 80 IA with Ministry of Commerce and Industry; and under the Industrial Park Scheme 2002, it was duly notified that industrial park developed by the assessee was eligible 100% exemption u/s 80 IA. It was never in dispute any of the major conditions laid down under the notification issued by the Government of India was ever violated. Such proposed

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - (1), PANAJI vs. M/S GOA STATE INFRASTRUCTURE DEVELOPMENT CORPORATION LIMITED , PANAJI

In the result, both the appeal of assessee and the revenue are dismissed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2014-15 Goa State Infrastructure Income Tax Officer, Ward- Development Corporation 1(1), Panaji – Goa 403 001. Ltd. Vs. 7Th Floor, Edc House, Dr. A. B. Road, Panaji, Goa 403001 (Pan: Blrgo3663C) (Appellant) (Respondent) & Assessment Year: 2014-15 Deputy Commissioner Of Goa State Infrastructure Income-Tax, Circle-1(1), Vs. Development Corporation Panaji, Goa Ltd., Panaji . (Appellant) (Respondent) Present For: Assessee By : Shri Jitendra Jain, Ar Department By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 15.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: Both These Cross Appeals Preferred By The Assessee & The Revenue Are Directed Against The Order Of Ld. Cit(A)-2, Panaji Vide Ita No. 143/Cit(A)-2/Pnj/2017-18 & Ita No. 42/Cit(A)-1/Pnj/2017-18 Dated 27.09.2018 For A.Y. 2014-15 Passed Against The Assessment Order U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Ito, Ward-1(1), Panaji-Goa Dated 19.12.2016. 2. Shri Jitendra Jain, Ar Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Appeared On Behalf Of The Revenue. M/S. Goa State Infrastructure Development Corporation Ltd. A.Y: 2015-16 3. The Only Issue Involved In These Two Cross Appeals Is In Relation To Disallowance Of Deduction Of Rs.3,37,35,560/- Claimed By The Assessee U/S. 80Ia Of The Act. The Assessee Is In Appeal In Respect Of Disallowance Of An Amount Of Rs.23,97,310/- & The Department Is In Appeal In Respect Of Relief Granted By The Ld. Cit(A) For Allowance Of Rs.3,13,38,250/-, Both Comprising The Total Claim Of Rs.3,37,35,560/-.

disallowed the claim by stating that the appellant is not a developer but a nodal agency. The AO placed reliance on the ratio of decision of Hon'ble ITAT 'C' Bench, Ahmedabad in the case of Gujarat Urban Development Co. Ltd. Vs DCIT (ITA.No.1972/AHD/2014). 4.3. On perusal of the aforesaid decision, it is found that the facts

GOA STATE INFRASTRUCTURE DEVLOPMENT CORPORATION LIMITED.,PANAJI vs. INCOME TAX OFFICER, WARD-1(1), , PANAJI

In the result, both the appeal of assessee and the revenue are dismissed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2014-15 Goa State Infrastructure Income Tax Officer, Ward- Development Corporation 1(1), Panaji – Goa 403 001. Ltd. Vs. 7Th Floor, Edc House, Dr. A. B. Road, Panaji, Goa 403001 (Pan: Blrgo3663C) (Appellant) (Respondent) & Assessment Year: 2014-15 Deputy Commissioner Of Goa State Infrastructure Income-Tax, Circle-1(1), Vs. Development Corporation Panaji, Goa Ltd., Panaji . (Appellant) (Respondent) Present For: Assessee By : Shri Jitendra Jain, Ar Department By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 15.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: Both These Cross Appeals Preferred By The Assessee & The Revenue Are Directed Against The Order Of Ld. Cit(A)-2, Panaji Vide Ita No. 143/Cit(A)-2/Pnj/2017-18 & Ita No. 42/Cit(A)-1/Pnj/2017-18 Dated 27.09.2018 For A.Y. 2014-15 Passed Against The Assessment Order U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Ito, Ward-1(1), Panaji-Goa Dated 19.12.2016. 2. Shri Jitendra Jain, Ar Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Appeared On Behalf Of The Revenue. M/S. Goa State Infrastructure Development Corporation Ltd. A.Y: 2015-16 3. The Only Issue Involved In These Two Cross Appeals Is In Relation To Disallowance Of Deduction Of Rs.3,37,35,560/- Claimed By The Assessee U/S. 80Ia Of The Act. The Assessee Is In Appeal In Respect Of Disallowance Of An Amount Of Rs.23,97,310/- & The Department Is In Appeal In Respect Of Relief Granted By The Ld. Cit(A) For Allowance Of Rs.3,13,38,250/-, Both Comprising The Total Claim Of Rs.3,37,35,560/-.

disallowed the claim by stating that the appellant is not a developer but a nodal agency. The AO placed reliance on the ratio of decision of Hon'ble ITAT 'C' Bench, Ahmedabad in the case of Gujarat Urban Development Co. Ltd. Vs DCIT (ITA.No.1972/AHD/2014). 4.3. On perusal of the aforesaid decision, it is found that the facts

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].

80-AC(ii) by Finance Act, 2018 came into play only in 2020-21 assessment year. Thus, no doubt Section 80AC as amended by the Finance Act, 2018 mandated that even for claiming deduction claimed u/s 80P, the return of income was to be filed before the due date as specified u/s 139(1) of the Act. However

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].

80-AC(ii) by Finance Act, 2018 came into play only in 2020-21 assessment year. Thus, no doubt Section 80AC as amended by the Finance Act, 2018 mandated that even for claiming deduction claimed u/s 80P, the return of income was to be filed before the due date as specified u/s 139(1) of the Act. However

GOA CARBON LTD.,PANAJI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1 (1), PANAJI

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri C.M. Garg & Shri Girish Agrawal

Section 80 HHC. 16. Having regard to emerging position, what has been disallowed pursuant to Explanation (baa) to Section 80HHC

M/S CHOWGULE AND COMPANY (SALT) PVT. LTD,MORMUGAO vs. THE ACIT, CIRCLE - 2, MARGAO

The appeal of the assessee is partly allowed in terms of aforesaid observation

Bench: Shri Ravish Sood & Shri Jamlappa D. Battullआयकर अपील सं. / Ita No. : 390/Pan/2017 करधििाारण वर्ा / Assessment Year : 2012-2013 M/S Chowgule & Company (Salt) Pvt Ltd., Chowgule House, Mormugao Harbour, Goa – 403803. Pan: Aabcc 5595 J . . . . . . . अपीलार्थी / Appellant बिाम / V/S Asstt. Commissioner Of Income Tax, Circle-2, Margao, Goa. . . . . . . . प्रत्यर्थी / Respondent द्वारा / Appearances Assessee By : Ms Hiral Sejpal Revenue By : Shri Sourabh Nayak सुनवाई की तारीख / Date Of Conclusive Hearing : 24/02/2022 घोषणा की तारीख / Date Of Pronouncement : 29/04/2022 आदेश / Order Per Jamlappa D Battull Am; The Present Appeal Filed By The Appellant Assessee Is Directed Against The Order Of Commissioner Of Income Tax- Appeals, Panaji-1 [For Short “Cit(A)”] Dt. 09/10/2017 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which In Turn Tousled Out Of Order Of Assessment Of Assistant Commissioner Of Income Tax-Circle-2, Margoa [For Short “Ao”] Dt. 27/07/2014 Passed U/S 143(3) Of The Act, For The Assessment Year [For Short “Ay”] 2012-2013. Itat-Panaji Page 1 Of 23

disallowance was also imputed by addition into the computation of book profit under the MAT provisions of section 115JB. 6.4 Secondly, the appellant in its return claimed a depreciation @80

M/S SIDDHARTH NATURAL FOOD RESOURCES PRIVATE LIMITED,KUNDAIM vs. ACIT, CIRCLE - 2(1), PANAJI

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

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.187/Pan/2017 िनधा"रण वष" / Assessment Year : 2009-10 M/S. Siddharth Natural Food Resources Private Limited, Plot No.83, Kundaim Industrial Estate, Kundaim, Panaji- 403001. .......अपीलाथ" / Appellant Pan : Aalcs5815K बनाम / V/S. Acit, Circle-2(1), ……""यथ" / Respondent Panaji. Assessee By : None Revenue By : Shri Sourabh Nayak सुनवाई क" तारीख / Date Of Hearing : 09.11.2021 घोषणा क" तारीख / Date Of Pronouncement : 12.11.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-1, Panaji (‘Cit(A)’ For Short) Dated 08.02.2017 For The Assessment Year 2009-10. 2. The Appellant Raised The Following Grounds Of Appeal :- “1) The Order Of The Learned Cit(A) Is Bad In Law & Is Void-Ab-Initio. 2) The Assessment Order Passed By The Ld.Ao U/S 143(3) Of The Income Tax Act, 1961, Is Without Jurisdiction & Bad In Law. 3) The Ld.Cit(A) Has Erred In Sustaining The Disallowance Of Rs.3,35,25,800/- Made By The Ao, Whereas The Deduction Claimed By The Assessee U/S 80Ib Was Only Rs.50,00,194/-. 4) The Ld Ao Has Erred In Disallowing The Profit As Per Profit & Loss Account Of Rs.3,35,25,800/- Whereas The Profit As Per The Income Tax Act, 1961 Was Only Rs.50,00,194/- Which Was Claimed As Deduction U/S 80Ib In The Return Of Income Filled By The Assessee. Hence The Maximum Addition By Way Of Disallowance Of Assessee Claim Of Deduction U/S 80Ib Can Be Only Rs.50,00,194/-.

disallowance of assessee claim of deduction u/s 80IB can be only Rs.50,00,194/-. 2 5) The ld.CIT(A) has failed to allow the eligible deduction u/s 80IB of the Income Tax Act, 1961 to the assessee, inspite of complying with all the conditions as prescribed under the Act. 6) The ld. AO and CIT(A) has failed to understand

M/S GOA NATURAL FOODS PRIVATE LIMITED,KUNDAIM vs. ACIT, CIRCLE - 2(1), PANAJI

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

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.188/Pan/2017 िनधा"रण वष" / Assessment Year : 2009-10 M/S. Goa Natural Foods Pvt. Ltd., Plot No.37 & 38, Kundaim Industrial Estate, Kundaim, Panaji- 403001. .......अपीलाथ" / Appellant Pan : Aaccg7564Q बनाम / V/S. Acit, Circle-2(1), ……""यथ" / Respondent Panaji. Assessee By : None Revenue By : Shri Sourabh Nayak सुनवाई क" तारीख / Date Of Hearing : 08.11.2021 घोषणा क" तारीख / Date Of Pronouncement : 11.11.2021 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-1, Panaji (‘Cit(A)’ For Short) Dated 08.02.2017 For The Assessment Year 2009-10. 2. The Appellant Raised The Following Grounds Of Appeal :- “1) The Order Of The Learned Cit(A) Is Bad In Law & Is Void-Ab-Initio. 2) The Assessment Order Passed By The Ld.Ao U/S 143(3) Of The Income Tax Act, 1961, Is Without Jurisdiction & Bad In Law. 3) The Ld.Cit(A) Has Erred In Sustaining The Disallowance Of Rs.2,77,54,053/- Made By The Ao, Whereas The Deduction Claimed By The Assessee U/S 80Ib Was Only Rs.1,64,18,999/-. 4) The Ld Ao Has Erred In Disallowing The Profit As Per Profit & Loss Account Of Rs.2,77,54,053/- Whereas The Profit As Per The Income Tax Act, 1961 Was Only Rs.1,64,18,999/- Which Was Claimed As Deduction U/S 80Ib In The Return Of Income Filled By The Assessee. Hence The Maximum Addition By Way Of Disallowance Of Assessee Claim Of Deduction U/S 80Ib Can Be Only Rs.1,64,18,999/-.

disallowance of assessee claim of deduction u/s 80IB can be only Rs.1,64,18,999/-. 2 5) The ld.CIT(A) has failed to allow the eligible deduction u/s 80IB of the Income Tax Act, 1961 to the assessee, inspite of complying with all the conditions as prescribed under the Act. 6) The ld. AO and CIT(A) has failed

GANGADHAR NARSINGDAS AGRAWAL (HUF),MARGAO vs. ASSTT. COMM. OF INCOME TAX CIRCLE 1, MARGAO

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2011-12 M/S. Gangadhar Narsingdas Assistant Commissioner Of Agrawal (Huf) Income-Tax, Circle-1, 1St Floor, Anand Bhavan, Vs. Margao-Goa. Old Station Rod, Margao- Goa 403601 (Pan: Aabhg4804R) (Appellant) (Respondent) Present For: Appellant By : Shri Nishant Thakkar, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 16.06.2022 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. 42/Mrg/2014-15 Dated 16.03.2018 For A.Y. 2011-12 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, Margao, Goa Dated 25.03.2014. 2. Shri Nishant Thakkar, Advocate Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Appeared On Behalf Of The Revenue.

disallowance have to be effected. This court, we may note, on more than one occasion, has held that the onus is on the Revenue to establish that there is a proximate relationship between the expenditure and the exempt income. That is, the application of section 14A and rule 80

GRAMA SEVA SAHAKARI SANGH LTD,BELGAUM vs. INCOME TAX OFFICER, WARD - 1(4), BELAGAVI

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

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.01/Pan/2018 िनधा"रण वष" / Assessment Year : 2013-14 Grama Seva Sahakari Sangh Ltd., Sankonhatti, Tq: Athani, Dist. Belgaum. .......अपीलाथ" / Appellant Pan : Aaaag0157B बनाम / V/S. Ito, Ward-1(4), ……""यथ" / Respondent Belagavi. Assessee By : Shri Shivanand Halbhavi Revenue By : Shri Sourabh Nayak 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 Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Gulbarga (‘Cit(A)’ For Short) Dated 26.10.2017 For The Assessment Year 2013-14. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. The Learned A.O. & Learned Cit (A) Have Erred In Disallowing Deduction Claimed Under Section 80P(2)(A) By Treating Is As Income From Other Sources. 2. The Learned A.O. Has Erred In Treating Income From Business & Profession As Income From Other Sources. 3. The Learned Ao & Learned Cit(A) Have Wrongly Interpreted The Provisions Of Sec 80P(2)(D) By Not Treating As Co-Op. Societies. 4. The Learned Ao Has Wrongly Interpreted The Definition Of Co-Op Society Vide Sec. 2(19) Of The It Act, 1961 By Treating Those Entities Which Are Registered Under The Co-Op Societies, 1912(2 Of 1912), Or Under Any Other Law For The Time Being In Force In Any State For The Registration Of Co-Op Societies, As Not Being Co-Op Societies.

disallowed the deduction claimed u/s 80P(2)(d) without providing any proper reason and without providing any opportunities to the assessee to represent in this particular issue. 6. THAT the Learned CIT(A) has erred in deciding our case on the basis of judgment of Hon’ble Supreme Court in case of the Citizen Co-operative Society

HARDESH ORES PRIVATE LIMITED,MARGAO vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, MARGAO

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

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2012-13 M/S. Hardesh Ores Private Deputy Commissioner Of Limited Income-Tax, Circle-1(1), Villa Flores Da Silva, Vs. Margao, Goa. Erasmo Carvalho Street, Margao, Goa-403601. (Pan: Aaach4515J) (Appellant) (Respondent) Present For: Appellant By : Shri Nishant Thakkar, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 16.06.2022 Date Of Pronouncement : 02.09.2022 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

disallowance have to be effected. This court, we may note, on more than one occasion, has held that the onus is on the Revenue to establish that there is a proximate relationship between the expenditure and the exempt income. That is, the application of section 14A and rule 80

SHANTADURGA MULTI PURPOSE SOUHARDA SAHAKARI NIYAMIT,BELAGAVI vs. INCOME TAX OFFICER, WARD - 2, BELAGAVI

In the result, the two appeals filed by the assessee are allowed

Bench: Shri Pavan Kumar Gadalei T A. Nos. 203 &204/Pan/2025 (A.Y.2015-16 & A.Y.2016-17) Shantadurga Multi Purpose Vs National E – Souharda Sahakari Niyamit, Assessment Centre . Shop.No.13/14,Mangal Deep, Delhi-110001 Apartments Opp:Herwadkar, Belagavi-590006, Karnataka. Pan .No.Aahas7562F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Ramesh Mudhol.Ar Revenue By Smt. Manjula Thakur.Sr.Dr सुनवाई की तारीख/Date Of Hearing 10.09.2025 घोषणा की तारीख/Date Of Pronouncement 15.09.2025 Order Per Pavan Kumar Gadale, Jm: These Two Appeals Are Filed By The Assesse Against The Separate Orders Of National Faceless Appeal Centre (Nfac) Delhi / Cit(A) Passed U/Sec 250 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Order Of The Nfac/ Cit(A) Sustaining The Denial Of Claim Of Deduction Under Section 80P Of The Act Applying The Provisions Of Section 80Ac Of The Act. 2. Since Issues Involved In These Appeals Are Common & Identical, Hence They Are Clubbed, Heard & A Consolidated Order Is Passed. For The Sake Of Convenience

disallowance of deduction under section 80P of the Act overlooking the submissions and factual aspects.. The sole contentions of the Ld.AR that the revenue authorities have wrongly applied the provisions of section 80

SHANTADURGA MULTI PURPOSE SOUHARDA SAHAKARI NIYAMIT ,BELAGAVI vs. INCOME TAX OFFICER, WARD - 2, BELAGAVI

In the result, the two appeals filed by the assessee are allowed

Bench: Shri Pavan Kumar Gadalei T A. Nos. 203 &204/Pan/2025 (A.Y.2015-16 & A.Y.2016-17) Shantadurga Multi Purpose Vs National E – Souharda Sahakari Niyamit, Assessment Centre . Shop.No.13/14,Mangal Deep, Delhi-110001 Apartments Opp:Herwadkar, Belagavi-590006, Karnataka. Pan .No.Aahas7562F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Ramesh Mudhol.Ar Revenue By Smt. Manjula Thakur.Sr.Dr सुनवाई की तारीख/Date Of Hearing 10.09.2025 घोषणा की तारीख/Date Of Pronouncement 15.09.2025 Order Per Pavan Kumar Gadale, Jm: These Two Appeals Are Filed By The Assesse Against The Separate Orders Of National Faceless Appeal Centre (Nfac) Delhi / Cit(A) Passed U/Sec 250 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Order Of The Nfac/ Cit(A) Sustaining The Denial Of Claim Of Deduction Under Section 80P Of The Act Applying The Provisions Of Section 80Ac Of The Act. 2. Since Issues Involved In These Appeals Are Common & Identical, Hence They Are Clubbed, Heard & A Consolidated Order Is Passed. For The Sake Of Convenience

disallowance of deduction under section 80P of the Act overlooking the submissions and factual aspects.. The sole contentions of the Ld.AR that the revenue authorities have wrongly applied the provisions of section 80