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

THE PONDA EDUCATION SOCIETY EMPLOYEE CO-OPERATIVE CREDIT SOCIETY LIMITED,PONDA vs. INCOME TAX OFFICER, WARD - 2(2), PANAJI

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

68,206/-; respectively during the course of assessment hearing dated 20.12.2017 as upheld in the CIT(A)'s order. 2 ITA.No.132/PAN/2019 The Ponda Education Society Employee Co-operative Credit Society Ltd., Ponda Goa. 4. I have given my thoughtful consideration to vehement rival submissions. The first and foremost issue between the parties is that of assessee’s status

PRATHAMIK KRUSHI PATTIN SAHAKARI SANGH NYT,INGALI vs. INCOME TAX OFFICER, WARD - 1, NIPANI

In the result, appeals of the assessees are allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshali(Through Virtual Hearing) Prathamik Krushi Pattin Vs Ito, Ward-1, Sahakari Sangh Niyamit, Nipani Ingali, Tal - Chikodi, Dist. Belgaum, Karnataka. Pan: Aaaap 1335 L Appellant Respondent Directorate Of Health Services Vs Ito, Ward-1(4), Employees Co-Op. Credit Panaji-Goa. Society Ltd., Campal, Panji. Pan: Aaaad 8637 P Appellant Respondent Vyavasaya Seva Sahakari Vs Ito, Ward-2, Sangha Ltd., Kadatoka, Karwar. Honnavar, Karnataka. Pan: Aaaav 0321 N Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

RAMANAGULI GROUP SEVA SAHAKARI SANGHA LIMITED,ANKOLA vs. INCOME TAX OFFICER, WARD - 2, KARWAR

In the result, appeals of the assessees are allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshali(Through Virtual Hearing) Prathamik Krushi Pattin Vs Ito, Ward-1, Sahakari Sangh Niyamit, Nipani Ingali, Tal - Chikodi, Dist. Belgaum, Karnataka. Pan: Aaaap 1335 L Appellant Respondent Directorate Of Health Services Vs Ito, Ward-1(4), Employees Co-Op. Credit Panaji-Goa. Society Ltd., Campal, Panji. Pan: Aaaad 8637 P Appellant Respondent Vyavasaya Seva Sahakari Vs Ito, Ward-2, Sangha Ltd., Kadatoka, Karwar. Honnavar, Karnataka. Pan: Aaaav 0321 N Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

DIRECTORATE OF HEALTH SERVICES EMPLOYEES CO-OPERATIVE SOCIETY LTD,PANAJI vs. INCOME TAX OFFICER, WARD 1(4), PANAJI

In the result, appeals of the assessees are allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshali(Through Virtual Hearing) Prathamik Krushi Pattin Vs Ito, Ward-1, Sahakari Sangh Niyamit, Nipani Ingali, Tal - Chikodi, Dist. Belgaum, Karnataka. Pan: Aaaap 1335 L Appellant Respondent Directorate Of Health Services Vs Ito, Ward-1(4), Employees Co-Op. Credit Panaji-Goa. Society Ltd., Campal, Panji. Pan: Aaaad 8637 P Appellant Respondent Vyavasaya Seva Sahakari Vs Ito, Ward-2, Sangha Ltd., Kadatoka, Karwar. Honnavar, Karnataka. Pan: Aaaav 0321 N Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

VYAVASAYA SEVA SAHAKARI SANGHA LIMITED,KADATOKA vs. INCOME TAX OFFICER, WARD - 2, KARWAR

In the result, appeals of the assessees are allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshali(Through Virtual Hearing) Prathamik Krushi Pattin Vs Ito, Ward-1, Sahakari Sangh Niyamit, Nipani Ingali, Tal - Chikodi, Dist. Belgaum, Karnataka. Pan: Aaaap 1335 L Appellant Respondent Directorate Of Health Services Vs Ito, Ward-1(4), Employees Co-Op. Credit Panaji-Goa. Society Ltd., Campal, Panji. Pan: Aaaad 8637 P Appellant Respondent Vyavasaya Seva Sahakari Vs Ito, Ward-2, Sangha Ltd., Kadatoka, Karwar. Honnavar, Karnataka. Pan: Aaaav 0321 N Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

SHREE ADINATH MINORITY CREDIT SOUHARD SAHAKARI LTD,BELGAUM vs. INCOME TAX OFFICER, WARD - 1(3), BELAGAVI

In the result, appeals of the assessees are allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshali(Through Virtual Hearing) Prathamik Krushi Pattin Vs Ito, Ward-1, Sahakari Sangh Niyamit, Nipani Ingali, Tal - Chikodi, Dist. Belgaum, Karnataka. Pan: Aaaap 1335 L Appellant Respondent Directorate Of Health Services Vs Ito, Ward-1(4), Employees Co-Op. Credit Panaji-Goa. Society Ltd., Campal, Panji. Pan: Aaaad 8637 P Appellant Respondent Vyavasaya Seva Sahakari Vs Ito, Ward-2, Sangha Ltd., Kadatoka, Karwar. Honnavar, Karnataka. Pan: Aaaav 0321 N Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

THE SHIRODA PROGRESSIVE URBAN CO-OPERATIVE CREDIT SOCIETY LIMITED,PHONDA vs. INCOME TAX OFFICER, WARD -2(3), PANAJI

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.(Through Web-Based Video Conferencing Platform) The Parshwanath Co-Op. Vs Pr.Cit, Hubballi. Credit Society Ltd., 535, 536, 1St Floor, Padmavati Chambers, Kulkarni Galli, Belgaum. Pan: Aaaat 4145 L Appellant Respondent Candolim Urban Co-Op. Credit Vs Ito, Ward-2(1), Society Ltd., St.Joseph Panaji, Goa. Apartment, Near Football Ground, Candolim, Bardez. Pan: Aabac 2053 P Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

THE BARDEZ BAZAR CONSUMERS CO-OPERATIVE SOCIETY LIMITED,MAPUSA vs. ACIT, CIRCLE - 2(1), PANAJI

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.(Through Web-Based Video Conferencing Platform) The Parshwanath Co-Op. Vs Pr.Cit, Hubballi. Credit Society Ltd., 535, 536, 1St Floor, Padmavati Chambers, Kulkarni Galli, Belgaum. Pan: Aaaat 4145 L Appellant Respondent Candolim Urban Co-Op. Credit Vs Ito, Ward-2(1), Society Ltd., St.Joseph Panaji, Goa. Apartment, Near Football Ground, Candolim, Bardez. Pan: Aabac 2053 P Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

THE BARDEZ BAZAR CONSUMERS CO-OPERATIVE SOCIETY LIMITED,MAPUSA vs. ACIT, CIRCLE - 2(1), PANAJI

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.(Through Web-Based Video Conferencing Platform) The Parshwanath Co-Op. Vs Pr.Cit, Hubballi. Credit Society Ltd., 535, 536, 1St Floor, Padmavati Chambers, Kulkarni Galli, Belgaum. Pan: Aaaat 4145 L Appellant Respondent Candolim Urban Co-Op. Credit Vs Ito, Ward-2(1), Society Ltd., St.Joseph Panaji, Goa. Apartment, Near Football Ground, Candolim, Bardez. Pan: Aabac 2053 P Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

THE PARSHWANATH CO-OP. CREDIT SOCIETY LIMITED,BELGAUM vs. PR. CIT, HUBBALI

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.(Through Web-Based Video Conferencing Platform) The Parshwanath Co-Op. Vs Pr.Cit, Hubballi. Credit Society Ltd., 535, 536, 1St Floor, Padmavati Chambers, Kulkarni Galli, Belgaum. Pan: Aaaat 4145 L Appellant Respondent Candolim Urban Co-Op. Credit Vs Ito, Ward-2(1), Society Ltd., St.Joseph Panaji, Goa. Apartment, Near Football Ground, Candolim, Bardez. Pan: Aabac 2053 P Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

THE CANDOLIM URBAN CO - OPERATIVE CREDIT SOCIETY LIMITED,CANDOLIM, GOA vs. INCOME TAX OFFICER, WARD - 2(1), PANAJI

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.(Through Web-Based Video Conferencing Platform) The Parshwanath Co-Op. Vs Pr.Cit, Hubballi. Credit Society Ltd., 535, 536, 1St Floor, Padmavati Chambers, Kulkarni Galli, Belgaum. Pan: Aaaat 4145 L Appellant Respondent Candolim Urban Co-Op. Credit Vs Ito, Ward-2(1), Society Ltd., St.Joseph Panaji, Goa. Apartment, Near Football Ground, Candolim, Bardez. Pan: Aabac 2053 P Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

M/S THE QUEPEM URBAN CO-OP. CREDIT SOCIETY LTD.,QUEPEM vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE- 1, MARGAO

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.(Through Web-Based Video Conferencing Platform) The Parshwanath Co-Op. Vs Pr.Cit, Hubballi. Credit Society Ltd., 535, 536, 1St Floor, Padmavati Chambers, Kulkarni Galli, Belgaum. Pan: Aaaat 4145 L Appellant Respondent Candolim Urban Co-Op. Credit Vs Ito, Ward-2(1), Society Ltd., St.Joseph Panaji, Goa. Apartment, Near Football Ground, Candolim, Bardez. Pan: Aabac 2053 P Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

THE BHANDARI CO-OP CREDIT SOIETY LIMITED,PANAJI vs. INCOME TAX OFFICER, WARD - 1(5), PANAJI

In the result, appeals of the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

PRIMARY AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LTD,KONNUR vs. INCOME TAX OFFICER, WARD - 1, GOKAK

In the result, appeals of the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

THE BHANDARI CO-OP CREDIT SOIETY LIMITED,PANAJI vs. INCOME TAX OFFICER, WARD - 1(5), PANAJI

In the result, appeals of the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

PRIMARY AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LTD,KONNUR vs. INCOME TAX OFFICER, WARD - 1, GOKAK

In the result, appeals of the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

PRIMARY AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LTD,KONNUR vs. INCOME TAX OFFICER, WARD - 1, GOKAK

In the result, appeals of the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing

THE PIRNA URBAN CO-OP. CREDIT SOCIETY LIMITED,PIRNA, GOA vs. THE INCOME TAX OFFICER, WARD-2(3), PANAJI

In the result, appeals of the assessees are allowed and the Revenues are dismissed

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.(Through Web-Based Video Conferencing Platform) Shri Lokakalyan Souhard Vs Pr.Cit, Belagavi. Sahakari Niyamit, Jatrat, Tal- Chikodi, Dist. Belagavi. Pan: Aaajs 2263 H Appellant Respondent Shree Kalika Urban Co-Op Vs Acit, Circle-2(1), Credit Society Ltd., Shop Panaji. No.3, Rituraj Plaza, Keni Wada, Mapusa, Bardez, Goa. Pan: Aacas 1697 Q Appellant Respondent Goa Bagayatdar Sahakari Vs Acit, Circle-2(1), Kharedi Vikri Saunstha Panaji. Maryadit, Bagayatdar Bhavan, Ponda, Upper Bazar, Goa. Pan: Aaaag 2147 B Appellant Respondent The Marcela Urban Co-Op Vs Ito, Ward-2(3), Credit Society Ltd., Janavikas Panaji. Building, Near Kadamba Bus Stand, Marcela, North Goa, Goa. Pan: Aadat 5762 G Appellant Respondent

120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed by the appellant held that the failure of the Assessing