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)

section 68 of the Act made by the Assessing Officer. 2. The brief facts of the case are that, the assesse company is engaged in the business of manufacturing of poultry/animal feeds and running poultry farms. The 2 ITA. No..217/PAN/2023 Kwality Animal Feeds Pvt Ltd. assessee has filed the return of income on 27

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].

27 ITR 630 (PAT.)] Per contra, if assessee prove of having sufficient SBN balance in hand prior to such demonetisation deposits, then succeeds in explaining nature & source in view of ‘Narendra G. Goradia vs. CIT [1998] 234 ITR 571 (Bom)]. Since neither party proved their version of contention which could pass test of reasonability for acceptance, therefore to balance

SHRI JINNAPPANNA CHOUGULE LALBAHADUR CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,BELGAUM vs. INCOME TAX OFFICER, BELGAUM

In the result, the three appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

section 80P(2)(a)(i) of the Act of Rs.22,60,074/- and similarly find that the assessee has debited to profit & loss account income tax paid of Rs.6,08,090/- and provision for bad and doubtful debts of Rs.8,00,000/- which is not admissible claim and made disallowance and assessed the total income of Rs.36,68

SHRI JINNAPPANNA CHOUGULE LALBAHADUR CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,2471, LALBAHADUR AKKAMAHADEVI CHOWK, SHIRGUPPI ATH vs. INCOME TAX OFFICER, BELGAUM

In the result, the three appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

section 80P(2)(a)(i) of the Act of Rs.22,60,074/- and similarly find that the assessee has debited to profit & loss account income tax paid of Rs.6,08,090/- and provision for bad and doubtful debts of Rs.8,00,000/- which is not admissible claim and made disallowance and assessed the total income of Rs.36,68

SHRI JINNAPPANNA CHOUGULE LALBAHADUR CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,BELGAUM vs. INCOME TAX OFFICER, BELGAUM

In the result, the three appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

section 80P(2)(a)(i) of the Act of Rs.22,60,074/- and similarly find that the assessee has debited to profit & loss account income tax paid of Rs.6,08,090/- and provision for bad and doubtful debts of Rs.8,00,000/- which is not admissible claim and made disallowance and assessed the total income of Rs.36,68

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].

27 of P/B) that; entrance fees charged on admission to membership and donation constitutes the main income of the society. In nutshell the appellant is a discretionary entity whose membership is restricted to specific family and where individual share of beneficiary members are unknown or indeterminate for the purpose of the Act. ITAT-Panaji Page 7 of 18 Shri Rampurush

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].

27 of P/B) that; entrance fees charged on admission to membership and donation constitutes the main income of the society. In nutshell the appellant is a discretionary entity whose membership is restricted to specific family and where individual share of beneficiary members are unknown or indeterminate for the purpose of the Act. ITAT-Panaji Page 7 of 18 Shri Rampurush

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PANAJI, AYAKAR BHAWAN vs. VPK URBAN COOPERATIVE CREDIT SOCIETY , VPK BHAWAN

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya

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

27 42/PAN/2025 2017-18 Co-op Credit AAAAV0158M Panaji Chougule Society Limited National Kaiga Project Faceless e- 28 62/PAN/2025 2015-16 Employees Thrift AABAK8625R None Assessment And Credit Society centre, Delhi VPK Urban Co- Income Tax Officer Mr. Shyam J 29 252/PAN/2024 2015-16 AAJV0180G op Credit Ward -2(4), Panaji Kamat Society Page 3 of 36 Akshaya