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

section 143(3) of the I.T. Act, 1961. Further, the investment made in shares of Sesa Goa Ltd., as is evident from the audited books of account is out of surplus money only and no borrowed funds were utilized. The assessee-company purchased 3,38,03,812 equity shares of M/s. Sesa

M/S ADITI SCANS PVT. LTD,BIJAPUR vs. ACIT, CIRCLE - 1, BIJAPUR

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

Bench: Shri Laliet Kumar, Jm & Dr. Mitha Lal Meena, Am M/S Aditi Scans Pvt. Ltd. Vs Acit, Circle-1, Bijapur Shiva Kunja Chalukya Nagar (East) Solapur Road, Vijaypur, Vijaypur Pan No.Aagca 7255 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधााररती की ओर से /Assessee By : Shri Prasanth G.S., Ca राजस्व की ओर से /Revenue By : Shri Prabhat Jha, Citdr सुनवाई की तारीख / Date Of Hearing : 07/10/2021 घोषणा की तारीख/Date Of Pronouncement : 07/10/2021 आदेश / O R D E R Per Bench : This An Appeal Filed By The Revenue Against The Order Passed By The Cit(A), Gulbarga, Dated 29.11.2017 For The Assessment Year 2009- 2010, On The Following Grounds :- The Order Of The Learned Cit(A) In So Far As It Is Against The 1. Appellant, Is Opposed To Law, Weight Of Evidence, Natural Justice, Probabilities, Facts & Circumstances Of The Appellant'S Case. The Appellant Denies Itself Liable To Be Assessed On A Total Loss 2. Of Rs. 15,76,829/- As Against The Lossof Rs.75,46,930/- Under The Facts & Circumstances Of The Case. The Authorities Below Erred In Treating The Share Capital Of Rs. 3. 13,75,000/- As Unexplained Money Under Section 68 Of The Act Under The Facts & Circumstances Of The Case. The Order Of The Authorities Below Is Bad In Law As The Amount 4. Of Rs. 13,75,000/- Cannot Be Brought To Tax In The Hands Of The Appellant As The Mandatory Conditions To Invoke Section 68 Of The Act Have Not Been Satisfied Under The Facts & Circumstances Of The Case.

68 were treated asunexplained cash credits of the Income Tax Act, 1961 With regard to the increase in unsecured loans, the AR was requested to prove the identity of the person, thereir capacity to lend the money and the mode of payment etc. the AR here also was ot able to prove the loan creditor by giving full name

SHREE MALLIKARJUN SHIPPING PRIVATE LIMITED,VASCO vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), PANAJI

section 143(3) of the Act on 29.12.2009 accepting the returned income. There was survey operations u/sec133A of the Act on 22.09.2011 and as a result of survey the case was reopened u/sec147 of the Act and assessment was completed u/se 143(3)r.w.s147 of the Act on 28.03.2013 with the assessed income of Rs.1,16,96,177/-. Further

MR. MALLIKARJUN APPANNA ITI,GOKAK vs. INCOME TAX OFFICER, WARD - 1, GOKAK

In the result, the appeal of the assessee is partly allowed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

68, 69, 69A, 69B, 69C or 69D are not attracted to levy tax under section 115BBE. The assessee declared an amount in the return of income u/s 139. On the basis of the declared income which was found in survey the application of section 115BBE is unjustified. The concealment, which is found during the time of survey

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

143(3) of the Income Tax Act, 1961 (in short “the Act”). Heard both the parties at length. Case file perused. 2. The assessee pleads the following substantive ground in the instant appeal : 2 ITA.No.90/PAN./2023 1. “Because, the learned Commissioner of Income Tax (Appeals) and Assessing Officer denied the deduction claimed under section

LATE SHRI ANAND ALIAS VISHWANATH MAMANI, THROUGH HIS LEGAL HEIR SMT. RATNA ANAND MAMANI,BELAGAVI vs. THE INCOME TAX OFFICER, WARD -1 BELAGAVI, BELAGAVI

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

Bench: Shri Pavan Kumar Gadalei T A. No.352/Pan/2025 (A.Y. 2017-18) Late Shri Anand Alias Vs Ito-Ward-1, Vishwanath Mamani Through Feroj Khimjibhai Cpx, . His Legal Heir Smt.Ratna Civil Hospital Road Anand Mamani, Belagavi-590001. 3138/3, Ramapur Site, Karnataka. Saundatti, Belagavi-591126, Karnataka. Pan,No.Avhpm6615P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Sri.Shivananad Halbhavi.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 03.02.2026 घोषणा की तारीख/Date Of Pronouncement 04.02.2026 Order Per Pavan Kumar Gadale ,Jm: The Assesse Has Filed The Appeal Against The Order Of The Nfac/Cit(A) Passed U/Sec143(3) & U/Sec 250 Of The Act. The Assesee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Addition Of Unexplained Cash Deposits Under Section 68 Of The Act Made By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assesse Has Filed The Return Of Income For A.Y.2017-18 On 05.08.2017 Disclosing A Total Income Of Rs.11,93,580/- & The Case

section 68 of the Act and made addition of unexplained cash deposits of Rs.28,53,000/- and assessed the total income of Rs.40,46,580/- and passed the order u/sec 143

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

143(3) of the Income Tax Act, 1961 [In short “the Act”]. 2. Heard all the assessees’ as well as the department. Case files perused. 3. It emerges during the course of hearing that these three assessees’ identical sole substantive grievance challenges correctness of both the lower authorities action denying them section 80P(2)(a)(i) deductions of Rs.34

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

143(3) of the Income Tax Act, 1961 [In short “the Act”]. 2. Heard all the assessees’ as well as the department. Case files perused. 3. It emerges during the course of hearing that these three assessees’ identical sole substantive grievance challenges correctness of both the lower authorities action denying them section 80P(2)(a)(i) deductions of Rs.34

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara

143(3) of the Income Tax Act, 1961 [In short “the Act”]. 2. Heard all the assessees’ as well as the department. Case files perused. 3. It emerges during the course of hearing that these three assessees’ identical sole substantive grievance challenges correctness of both the lower authorities action denying them section 80P(2)(a)(i) deductions of Rs.34

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)

section 68 of the Act of Rs.80,33,000/- and finally assessed the total income of Rs.1,91,33,725/- and passed the order u/sec 143

NASALAPUR MAHILA PATTINA SAHAKARI SANGH NIYAMIT,RAIBAG vs. INCOME TAX OFFICER, WARD - 4, BELAGAVI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.185/Pan/2024 (A.Y. 2017-18 ) Nasalapur Mahila Pattin Vs I.T.O Ward-4, Sahakari Sangh Niyamit, Civil Hospital Road, . Nasalapur, Belgaum-590001. Chikodi, Karnataka. Belgaum-591213, . Karnataka. Pan .No. Aacan5745N (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri.Chetan Chougle.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr

section 68 of the Act and made addition of unexplained cash credits and assessed the total income of Rs.48,16,818/- and passed the order u/sec 143

LAXMI NARCINVA URBAN CO-OPERATIVE CREDIT SOCIETY LIMITED,MARGAO vs. INCOME TAX OFFICER, WARD - 3, MARGAO

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

Bench: Shri Pavan Kumar Gadalei T A. Nos.185/Pan/2025 (A.Y. 2017-18 ) Laxmi Narcinva Urban Vs Ito-Ward-3, Cooperative Credit Society Ltd, Blessings Pioneer . Katkar Guru Ashish Building, Complex, 1 St Floor,Rua Clovis Costa Old Market, Road, Margoa-403601, Margoa-403601, Goa. Goa. Pan .No. Aaajl1003E (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri. Pramod.Y.Vaidya.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 08.09.2025 घोषणा की तारीख/Date Of Pronouncement 09.09.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. 2. At The Time Of Hearing, The Ld.Ar Of The Assessee Submitted That There Is A Delay Of In Filing The Appeal Before The Hon’Ble Tribunal & The Assesse Has Filed The Application & Affidavit For Condonation Of Delay. Whereas, The Facts Mentioned In The Affidavit Are Reasonable & The Ld. Dr Has No Specific Objections.

section 68 of the Act and made addition of unexplained cash credits/ unexplained money and assessed the total income of Rs.36,92,400/- and passed the order u/sec 143

KWALITY ANIMAL FEEDS PRIVATE LIMITED,BELGAUM vs. ACIT CIRCLE 1 BELGAUM, BELGAUM

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. 217/Pan/2023 (A.Y. 2017-18) Kwality Animal Feeds Pvt Ltd, Vs Acit-Circle 1, 12, Kwality House, Civil Hospital Road, . Machhe Industrial Area, Belagavi-590001. Machhe, Karnataka. Belgaum-590014, Karnataka. Pan .No. Aabck0589J (अपीलाथ"/Appellant) (""यथ"/Respondent)

143(3) and u/sec 250 of the Act. The assessee has raised the grounds of appeal challenging the order of the CIT(A) sustaining the addition under section 68

SHRI LOKAKALYAN CREDIT SOUHARD SAHAKARI NYT,BELAGAVI vs. THE INCOME TAX OFFICER, WARD - 1, NIPANI

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

Bench: SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER I T A. Nos.332/PAN/2025 (Α.Υ. 2017-18) | Shree Lokakalyan Souharda Credit sahakari Niyamit, | Vs | I.T.O-Ward-1, Nemchand Building, | 1,A/P, Jatrat, Belgaum-591237, Karnataka. | | 747,AshokNagar, Nippani-591237, Karnataka. | PAN .No. AAAJS2263H | (अपीलार्थी/Appellant) | (प्रत्यर्थी/Respondent) | Assessee by | Shri. Veeranna M Murgod.AR | Revenue by | Smt.Rijula Uniyal.Sr.DR | सुनवाई की तारीख/Date of Hearing | 11.11.2025 | घोषणा की तारीख/Date of Prono

section 68 of the Act and made addition of unexplained cash credits of Rs.13,64,500/- and denied the claim of deduction u/sec80P of the Act and finally assessed the total income of Rs.42,88,149/- and passed the order u/sec 143

JAGDISH SAVANT,BELGAUM vs. INCOME TAX OFFICER, BELGAUM

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

Bench: Shri Pavan Kumar Gadalei T A. Nos.227/Pan/2025 (A.Y. 2017-18 ) Jagdish Shambhu Savant, Vs Ito-Ward-4, 102,Kaivalya Residency, Feroj Khimjibhai Cpx, . Budhwar Peth, Civil Hospital Road Belagavi-590006, Belagavi-590001. Karnataka. Karnataka. Pan/Gir No. Assps9453P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

section 68 of the Act and made addition of unexplained cash credits of Rs.15,71,780/- and similarly made addition of unexplained investment in flat u/sec69A of Rs.10,37,348 and finally assessed the total income of Rs.33,00,198/- and passed the order u/sec 143

ZUARI MANAGEMENT SERVICES LTD.,GOA vs. DEPUTY COMMISIONER OF INCOME-TAX, CIRCLE - 1, MARGAO

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2009-10 M/S Zuari Management Services Ltd. (Erstwhile Zuari Infrastructure & Developers Ltd., Formerly Zuari Sez Ltd.) Jai Kisaan Nagar, Zuari Nagar, Goa. Pan: Aaacz2903Q . . . . . . . Appellant V/S Dy. Commissioner Of Income Tax, Circle-1, Margao, Goa. . . . . . . . Respondent Represented Assessee By: Mr Salil Kapoor [‘Ld. Ar’] Revenue By: Mr Senthil Kumar N [‘Ld. Dr’] Date Of Conclusive Hearing : 29/01/2026 Date Of Pronouncement : 06/02/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income-

143(3) r.w.s. 263 of the Act wherein three additions were made first time viz; (1) disallowance of ₹3,56,51,678/- u/s 36(1)(iii) r.w.s. 37(1) of the Act representing interest paid to Holding company on deposits received from it, which in turn advanced to subsidiary without the payment of interest (interest waived off). (2) disallowance

SHRI VEERRANI MALLAMMA URBAN CREDIT SOUHARDA SAHAKARI LTD,BELGAVI vs. ITO, WARD 1(5), BELGAVI

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara

143(3) of the Income Tax Act, 1961 (in short "the Act"). 2. Heard the assessees as well as the department. Case files perused. 3. It emerges during the course of hearing that these assessee’s have raised their identical sole substantive grievance challenging correctness of both lower authority’s action disallowing section 80P deduction claims of Rs.8,68

SHRI SAI CREDIT SOUHARDA SAHAKARI NIYAMIT,CHIKODI vs. INCOME TAX OFFICER, WARD - 1, NIPANI

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara

143(3) of the Income Tax Act, 1961 (in short "the Act"). 2. Heard the assessees as well as the department. Case files perused. 3. It emerges during the course of hearing that these assessee’s have raised their identical sole substantive grievance challenging correctness of both lower authority’s action disallowing section 80P deduction claims of Rs.8,68