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

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

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

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

34,020/-. The same was processed under section 143(1) of the I.T. Act, 1961 on 19.05.2011. The case of the assessee was selected for scrutiny under CASS. Accordingly, notice under section 143(2) dated 24.08.2011 was issued and served on the assessee. In response to the notice, the assessee’s Authorised Representative appeared before

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

34,020/-. The same was processed under section 143(1) of the I.T. Act, 1961 on 19.05.2011. The case of the assessee was selected for scrutiny under CASS. Accordingly, notice under section 143(2) dated 24.08.2011 was issued and served on the assessee. In response to the notice, the assessee’s Authorised Representative appeared before

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

In the result, both appeals of the assessee are allowed

68,545/- based on the order of the AO-TP u/s 92CA of the Income Tax Act'1961, in spite of the fact that the assesse or their AE has not taken any benefit or exemption / deduction under the Income Tax Act. The Id AO(TP) and Dispute Resolution Panel-2, Bangalore, 4) has willfully ignored that the assesee

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

In the result, both appeals of the assessee are allowed

68,545/- based on the order of the AO-TP u/s 92CA of the Income Tax Act'1961, in spite of the fact that the assesse or their AE has not taken any benefit or exemption / deduction under the Income Tax Act. The Id AO(TP) and Dispute Resolution Panel-2, Bangalore, 4) has willfully ignored that the assesee

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 Rangekallu

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].

34,640/-. The case of the assessee selected for scrutiny u/s 143(2) of the Act to examine ‘large value cash deposit during demonetization compared to returned income’. Finding assessee’s explanation about nature & source of special bank note [‘SBN’ hereinafter] worth ₹10,46,000/- & ₹7,50,000/- deposited by her into Karnataka Bank & Syndicate Bank accounts respectively, unsatisfactory

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

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

68 of the Act as the cooperative society has not explained the sources of cash deposits in the bank account during demonetization period. The Ld.AR submitted that entire amount of demonetized currency during demonetization period are receipts from members on account of regular business transactions such as loan repayment, saving deposit, recurring deposit, pigmy collections etc. The members are recognized

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

68 of the Act as the cooperative society has not explained the sources of cash deposits in the bank account during demonetization period. The Ld.AR submitted that entire amount of demonetized currency during demonetization period are receipts from members on account of regular business transactions such as loan repayment, saving deposit, recurring deposit, pigmy collections etc. The members are recognized

SHRI SHRADHA CREDIT SOUHARD SAHAKARI NIYMIT NIPANI,NIPANI vs. ITO, WARD-2 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

68 of the Act as the cooperative society has not explained the sources of cash deposits in the bank account during demonetization period. The Ld.AR submitted that entire amount of demonetized currency during demonetization period are receipts from members on account of regular business transactions such as loan repayment, saving deposit, recurring deposit, pigmy collections etc. The members are recognized

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

68 of the Act as the cooperative society has not explained the sources of cash deposits in the bank account during demonetization period. The Ld.AR submitted that entire amount of demonetized currency during demonetization period are receipts from members on account of regular business transactions such as loan repayment, saving deposit, recurring deposit, pigmy collections etc. The members are recognized

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

68 of the Act as the cooperative society has not explained the sources of cash deposits in the bank account during demonetization period. The Ld.AR submitted that entire amount of demonetized currency during demonetization period are receipts from members on account of regular business transactions such as loan repayment, saving deposit, recurring deposit, pigmy collections etc. The members are recognized

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

68 of the Act as the cooperative society has not explained the sources of cash deposits in the bank account during demonetization period. The Ld.AR submitted that entire amount of demonetized currency during demonetization period are receipts from members on account of regular business transactions such as loan repayment, saving deposit, recurring deposit, pigmy collections etc. The members are recognized