THE MERCANTILE CO OP CREDIT SOCIETY LTD,BELAGAVI vs. ITO WARD 6 BELAGAVI, BELAGAVI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 97/Pan/2024 (A.Y. 2017-18 ) The Mercantile Co-Op Credit Ito-Ward-6, Vs Society Ltd. 1St Floor, Datta Civil Hospital Road, . Complex, Kadolkar Galli, Belagavi-590001. Belagavi-590001, Karnataka. Karnataka. . Pan .No.Aaaat5212E (अपीलाथ"/Appellant) (""यथ"/Respondent)

10,82,241/- and(ii) made addition under section 68 of the Act of Rs.80,33,000/- and finally

THE ATHANI CREDIT CO-OPERATIVE SOCIETY LIMITED,ATHANI vs. INCOME TAX OFFICER, WARD - 1, BELAGAVI

Appeal is partly allowed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak Ripote

68 of the Income Tax Act, for cash credits based on deposits in bank, without going through the books of accounts maintained by the Appellant. 6. The appellant craves leave to add and or alter any of the grounds of appeal before or at the time of hearing.” 3. Coming to the first and foremost issue of the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, UDUPI vs. M/S MANIPAL TECHNOLOGIES LIMITED, MANIPAL

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

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2013-14 Dcit, Circle-1, Udupi M/S. Manipal Technologies Limited, Vs. Udayavani Building, Manipal- 576104. Pan: Aabcm 9516 H (Appellant) (Respondent) Present For: Assessee By : Smt. Sheetal Borkar, Advocate Revenue By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 13.06.2022 Date Of Pronouncement : 15.06.2022 O R D E R Per Girish Agrawal: The Present Appeal Filed By The Department Is Arising Out Of The Order Of Commissioner Of Income Tax (Appeals), Mangaluru In Appeal No. Ita No. 10030/Udp/Cit(A)Mng/2016-17 Dated 27.11.2017 Against The Order Of Dcit, Circle- 1, Udupi Passed U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 29.03.2016. 2. There Are Six Grounds Of Appeal Taken By The Department In The Present Appeal, All Of Which Relate To The Disallowance Made U/S 14A Of The Act R.W.R. 8D(2)(Ii) & 8D(2)(Iii) Of The Income-Tax Rules, 1962 (Hereinafter Referred To As ‘The Rules), Amounting To Rs. 1,61,65,201/-.

section 10(34) of the Act. We are therefore of the view that it would be in the interest of equity and justice if the assessee makes its claim in this regard before the Assessing Officer. The Assessing Officer will examine the claim of the assessee and thereafter decide the issue in accordance with law and as explained

SHRI MAHALAXMI CREDIT SOUHARD SAHAKARI NIYAMIT,KUNNUR vs. INCOME TAX OFFICER, WARD - 1, NIPANI

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara

section 80P(2)(a)(i) deductions of Rs.34,04,313/- Rs.14,68,917/- and Rs.36,10,456/- respectively

SHRI BRAHMANATH CREDIT SOUHARDA SAHAKARI NIYAMIT,NIPANI vs. ITO, WARD - 1 , NIPANI

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara

section 80P(2)(a)(i) deductions of Rs.34,04,313/- Rs.14,68,917/- and Rs.36,10,456/- respectively

JAI HANUMAN CREDIT SOUHARD SAHAKARI LTD.,BELAGAVI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE- 2(1), BELAGAVI

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara

section 80P(2)(a)(i) deductions of Rs.34,04,313/- Rs.14,68,917/- and Rs.36,10,456/- respectively

SHRI RAMPURUSH MANDIR SOCIETY,CUNCOLIM vs. ASSISTANT DIRECTOR OF INCOME TAX - CPC, BANGALORE

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 75 & 76/Pan/2025 Assessment Year : 2021-22 & 2022-23 Shri Rampurush Mandir Society Veroda, Cuncolim, Salcete, Goa-403703. Pan : Aadas9268E . . . . . . . Appellant V/S Asstt. Director Of Income Tax, Cpc, Bengaluru. . . . . . . . Respondent Appearances Assessee By : Mr Narcinva Lotlikar [‘Ld. Ar’] Revenue By : Mr Ish Gupta [‘Ld. Dr’] Date Of Conclusive Hearing : 25/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; The Twin Appeals Of The Appellant Assessee Impugns Separate Din & Orders Both Dt. 10/03/2025 Passed By The Addl./Jt. Commissioner Of Income Tax, Appeals(2), Kolkata [‘Ld. Cit(A)/Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Emanated Out Of Respective Summary Assessment Dt. 23/09/2022 & 16/03/2023 Passed U/S 143(1) Of The Act By The National Faceless E-Asstt Centre [‘Ld. Ao’ Hereinafter] Anent To Assessment Years 2021- 22 & 2022-23 [‘Ays’ Hereinafter].

10 of 18 Shri Rampurush Mandir Society Vs CPC ITA Nos.75 & 76/PAN/2025 AY: 2021-22 & 2022-23 12. Now coming to applicability of s/s (2) of section 167B of the Act. There was much less to be convinced with the argument of the Ld. Gupta that, s/s (2) applies blanketly to all AOP/BOI. It is miscoined

SHRI RAMPURUSH MANDIR SOCIETY,CUNCOLIM vs. ASSISTANT DIRECTOR, CPC, BANGALORE

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 75 & 76/Pan/2025 Assessment Year : 2021-22 & 2022-23 Shri Rampurush Mandir Society Veroda, Cuncolim, Salcete, Goa-403703. Pan : Aadas9268E . . . . . . . Appellant V/S Asstt. Director Of Income Tax, Cpc, Bengaluru. . . . . . . . Respondent Appearances Assessee By : Mr Narcinva Lotlikar [‘Ld. Ar’] Revenue By : Mr Ish Gupta [‘Ld. Dr’] Date Of Conclusive Hearing : 25/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; The Twin Appeals Of The Appellant Assessee Impugns Separate Din & Orders Both Dt. 10/03/2025 Passed By The Addl./Jt. Commissioner Of Income Tax, Appeals(2), Kolkata [‘Ld. Cit(A)/Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Emanated Out Of Respective Summary Assessment Dt. 23/09/2022 & 16/03/2023 Passed U/S 143(1) Of The Act By The National Faceless E-Asstt Centre [‘Ld. Ao’ Hereinafter] Anent To Assessment Years 2021- 22 & 2022-23 [‘Ays’ Hereinafter].

10 of 18 Shri Rampurush Mandir Society Vs CPC ITA Nos.75 & 76/PAN/2025 AY: 2021-22 & 2022-23 12. Now coming to applicability of s/s (2) of section 167B of the Act. There was much less to be convinced with the argument of the Ld. Gupta that, s/s (2) applies blanketly to all AOP/BOI. It is miscoined

GOURISH GOPINATH DESAI ,KARWAR vs. ITO -2, KARWAR , UTTARA KANNADA DISTRICT

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

Bench: Shri Pavan Kumar Gadalei T A. Nos. 284,285 & 286/Pan/2025 (A.Y.2014-15 ) Gourish Gopinath Desai, Vs Ito-Ward-2, Katgal Kumta, Aayakar Bhavan, . Uttar Kannada-581444, Karwar-581301, Karnataka. Karnataka. Pan No:Bfwpd9695E

section 68 of the Act(i)opening balance of Rs.10,29,558/- and (ii) similarly Rs.9,94,319/- and assessed the total income of Rs.23,35,660/- and passed the order u/sec 144 r.w.s 147 of the Act dated 03.05.2023. 4. Aggrieved by the order, the assessee has filed an appeal before the CIT(A),whereas

GOURISH GOPINATH DESAI,UTTAR KANNADA vs. ITO -2, KARWAR, KARWAR

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

Bench: Shri Pavan Kumar Gadalei T A. Nos. 284,285 & 286/Pan/2025 (A.Y.2014-15 ) Gourish Gopinath Desai, Vs Ito-Ward-2, Katgal Kumta, Aayakar Bhavan, . Uttar Kannada-581444, Karwar-581301, Karnataka. Karnataka. Pan No:Bfwpd9695E

section 68 of the Act(i)opening balance of Rs.10,29,558/- and (ii) similarly Rs.9,94,319/- and assessed the total income of Rs.23,35,660/- and passed the order u/sec 144 r.w.s 147 of the Act dated 03.05.2023. 4. Aggrieved by the order, the assessee has filed an appeal before the CIT(A),whereas

GOURISH GOPINATH DESAI,UTTAR KANNADA vs. ITO -2, KARWAR, KARWAR

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

Bench: Shri Pavan Kumar Gadalei T A. Nos. 284,285 & 286/Pan/2025 (A.Y.2014-15 ) Gourish Gopinath Desai, Vs Ito-Ward-2, Katgal Kumta, Aayakar Bhavan, . Uttar Kannada-581444, Karwar-581301, Karnataka. Karnataka. Pan No:Bfwpd9695E

section 68 of the Act(i)opening balance of Rs.10,29,558/- and (ii) similarly Rs.9,94,319/- and assessed the total income of Rs.23,35,660/- and passed the order u/sec 144 r.w.s 147 of the Act dated 03.05.2023. 4. Aggrieved by the order, the assessee has filed an appeal before the CIT(A),whereas

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, MARGAO., MARGAO vs. M/S SALGAONCAR MINING INDUSTRIES PVT. LTD., PANAJI

In the result, the appeal filed by the Revenue in ITA

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

10, the ld. CIT(A) gave a categorically finding that in respect of these parties the amount outstanding was aggregating to Rs.7,70,44,710/- considering the submissions of the appellant that these parties are contractors with whom the assessee entered into a service cum purchase contract entitling the contractors to operate as well as a right

SALGAOCAR MINING INDUSTRIES PRIVATE LIMITED.,PANAJI vs. THE JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE., MARGAO

In the result, the appeal filed by the Revenue in ITA

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

10, the ld. CIT(A) gave a categorically finding that in respect of these parties the amount outstanding was aggregating to Rs.7,70,44,710/- considering the submissions of the appellant that these parties are contractors with whom the assessee entered into a service cum purchase contract entitling the contractors to operate as well as a right

SHASHIKALA BHIMACHARYA MALAGI,GOKAK, KARNATAKA vs. ITO, WARD-1, GOKAK, GOKAK, KARNATKA

The appeal is partly allowed in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 180/Pan/2023 Assessment Year : 2017-18 Shashikala Bhimacharya Malagi 0, Soubhagya, Kalyan Housing Colony, Gokak, Belgaum-591307 Pan : Bdypm3708B . . . . . . .Appellant V/S Income Tax Officer, Ward-1, Gokak. . . . . . . . Respondent Appearances Assessee By : Mr Himanshu Gandhi [‘Ld. Ar’] Revenue By : Mr Narendra Reddy [‘Ld. Dr’] Date Of Conclusive Hearing : 08/04/2025 Date Of Pronouncement : 09/04/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Assessee Impugns Din & Order No. 1055706480(1) Dt. 04/09/2023 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 Assessment Dt. 20/12/2019 Passed U/S 143(3) Of The Act Anent To Assessment Year 2017-18 [‘Ay’ Hereinafter].

10. Now next comes to a challenge of applicability of section 115BBE of the Act. The appellant denies the addition to be tax at accelerated rate of 60% as against 30% rate of tax which was prevalent till 31/03/2017. Per contra, the Revenue contended that, the provision of section 115BBE of the Act brought into statute first

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].

68 taxmann.com 298 (Ker)]. 5. Per contra, the Ld. DR Uniyal sought our attention to para 5 of the Ld. Co-ordinate bench’s decision and pressing into service subsequent decision of Hon’ble Kerala High ITAT-Panaji Page 3 of 10 Navanirman Multipurpose Co-op. Credit Society Ltd. Vs ITO ITA Nos.116/PAN/2025 AY: 2016-17 Court in ‘Nileshwar

SWAPNIL PRABHAKAR NAIK,KHANDOLA MARCELA vs. INCOME TAX OFFICER,WARD-1(3) PANAJI, PANAJI

The appeal of the assessee is partly allowed for statistical purpose

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

68 without appreciating the supporting ITAT-Panaji Page 3 of 10 Swapnil Prabhakar Naik Vs ITO ITA No.: 121/PAN/2025 AY: 2017-18 4. On the facts and circumstances of the case, the learned JCIT(A)-6, Mumbai and AO erred in making additions without appreciating the merits of the case and the relevant documentary evidences submitted in the course

SHREE MAHILA CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,BELAGAVI vs. ITO WARD 1 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

10 of 36 Akshaya Co-Op credit society Limited & others. We heard the rival submissions and perused the material on record. The sole matrix of the disputed issue envisaged by the Assessee Representatives is in respect of granting of deduction u/s 80P(2)(d) of the Act to the Cooperative Society. The Ld. AR submitted that the interest income

AKSHAYA CO-OPERATIVE CREDIT SOCIETY LIMITED,KARWAR vs. INCOME TAX OFFICER, WARD - 1(1), 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

10 of 36 Akshaya Co-Op credit society Limited & others. We heard the rival submissions and perused the material on record. The sole matrix of the disputed issue envisaged by the Assessee Representatives is in respect of granting of deduction u/s 80P(2)(d) of the Act to the Cooperative Society. The Ld. AR submitted that the interest income

SHIVAGIRI CO-OP CREDIT SOCIETY LTD,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1(3), 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

10 of 36 Akshaya Co-Op credit society Limited & others. We heard the rival submissions and perused the material on record. The sole matrix of the disputed issue envisaged by the Assessee Representatives is in respect of granting of deduction u/s 80P(2)(d) of the Act to the Cooperative Society. The Ld. AR submitted that the interest income