MR. AGNELO SOCORRO JOAQUIM VIEGAS,PANAJI vs. INCOME TAX OFFICER, WARD - 1(5), PANAJI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 069/Pan/2025 & Sa 06/Pan/2025 Assessment Year : 2011-12 Agnelo Socorro Joaquim Viegas H. No. 373, Galliwaddo, Taleigao, Caranzalem, Goa-403002. Pan : Akapv9049C . . . . . . . Appellant V/S Income Tax Officer, Ward-1(5), Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr Vinesh Pikale [‘Ld. Ar’] Revenue By : Mr Sanket Deshmukh[‘Ld. Dr’] Date Of Conclusive Hearing : 21/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Assessee Impugns Din & Order No. Itba/Apl/S/250/2024-25/1073026397(1) Dt. 07/02/2025 Passed By Addl./Jt. Commissioner Of Income Tax, Appeals(2), Ahmedabad [‘Ld. Cit(A)’] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’] Which In Turn Sprung Out Of Order Of Assessment Dt. 27/12/2018 Passed U/S 143(3) R.W.S. 147 Of The Act By The Income

section 5A of the Act is automatic or voluntary? And whether such application confined merely to returned income? 3. Succinctly stated facts of the case are that; 3.1 the assessee an individual was identified as non-filer. Upon receipt of information that for the year under consideration the assessee deposited cash of ₹12,32,000/- & ₹68

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)

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination of the assessment order, the ld. PCIT formed

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)

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination of the assessment order, the ld. PCIT formed

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)

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination of the assessment order, the ld. PCIT formed

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)

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination of the assessment order, the ld. PCIT formed

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)

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination of the assessment order, the ld. PCIT formed

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

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the ITA Nos. 40 & 42/PAN/2023 Prathamik Krushi Pattin Sahakari Sangh & Ors. assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently

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

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the ITA Nos. 40 & 42/PAN/2023 Prathamik Krushi Pattin Sahakari Sangh & Ors. assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently

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

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the ITA Nos. 40 & 42/PAN/2023 Prathamik Krushi Pattin Sahakari Sangh & Ors. assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently

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

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the ITA Nos. 40 & 42/PAN/2023 Prathamik Krushi Pattin Sahakari Sangh & Ors. assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently

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

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the ITA Nos. 40 & 42/PAN/2023 Prathamik Krushi Pattin Sahakari Sangh & Ors. assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently

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

32,86,382/- under the provisions of section 80P of the Income The Parshwanath Co-op Credit Society Ltd. & Ors. Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination

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

32,86,382/- under the provisions of section 80P of the Income The Parshwanath Co-op Credit Society Ltd. & Ors. Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination

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

32,86,382/- under the provisions of section 80P of the Income The Parshwanath Co-op Credit Society Ltd. & Ors. Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination

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

32,86,382/- under the provisions of section 80P of the Income The Parshwanath Co-op Credit Society Ltd. & Ors. Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination

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

32,86,382/- under the provisions of section 80P of the Income The Parshwanath Co-op Credit Society Ltd. & Ors. Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination

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

32,86,382/- under the provisions of section 80P of the Income The Parshwanath Co-op Credit Society Ltd. & Ors. Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2 (1), PANAJI., PANAJI vs. M/S SHREE KALIKA URBAN CO-OP. CREDIT SOCIETY LIMITED , MAPUSA

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

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination of the assessment order, the ld. PCIT formed

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2 (1), PANAJI., PANAJI vs. M/S GOA BAGAYATDAR SAHAKARI KHAREDI VIKRI SAUNSTHA MARYADIT, PONDA

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

32,86,382/- under the provisions of section 80P of the Income Tax Act, 1961 („the Act‟). Against the said return of income, the assessment was completed by the Assessing Officer accepting the returned income vide order dated 19.11.2019 passed u/s 143(3) of the Act. 4. Subsequently, on examination of the assessment order, the ld. PCIT formed