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 by the Revenue

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 by the Revenue

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)

68,721/- by taking note of the fact that these amounts were written off in the books of account and offered to tax in the subsequent year and the balance amount of Rs.51,96,21,993/- was deleted by the ld. CIT(A). During the course of proceedings before the ld. CIT(A), the assessee company filed details

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)

68,721/- by taking note of the fact that these amounts were written off in the books of account and offered to tax in the subsequent year and the balance amount of Rs.51,96,21,993/- was deleted by the ld. CIT(A). During the course of proceedings before the ld. CIT(A), the assessee company filed details

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

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 derived

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 derived

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 derived

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 derived

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

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 derived

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

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 derived

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

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 derived

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

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 derived

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

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 derived

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

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 derived

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

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 derived

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

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 derived

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

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 derived

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

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 derived

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

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 derived