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

SADASHIV B DALAWAI,RAIBAG vs. INCOME TAX DEPARTMENT, ASSESSMENT UNIT, DELHI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 307/Pan/2024 Assessment Year : 2020-21 Sadashiv B Dalawai At Post Shiragur Tal.: Raibag, Dist. Belgaum Pan : Bdrpd7066A . . . . . . . Applicant V/S Income Tax Officer/Itd, Belgaum/New Delhi. . . . . . . . Respondent Appearances Assessee By : Mrs Viramma Muranal [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 25/02/2025 घोषणा की तारीख / Date Of Pronouncement : 03/03/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Assessee Impugns Din & Order Itba/Nfac/S/250/2024-25/10703226271(1) Dt. 13/11/2024 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. 21/09/2022 Passed U/S 144 Of The Act By The National Faceless E-Asstt Centre [‘Ld. Ao’ Hereinafter] Anent To Assessment Year 2020-21[‘Ay’ Hereinafter].

68 of the Act as unexplained cash credit. Further when claim of deduction of ₹35,24,163/- & ₹1,50,000/- made respectively u/s 80G and 80C u/c VI-A of the Act remained unsubstantiated by the assessee, the said claims were also treated as bogus and thus disallowed while framing the assessment to the best of judgement

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)

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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)

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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)

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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)

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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)

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

M/S RAVIKIRAN CO-OPERATIVE CREDIT SOCIETY LIMITED,BELAGAVI vs. PRINCIPAL COMMISSIONER OF INCOME TAX , HUBLI

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhurysl.

section 80P(2)(d) of the Act or not?. The Pune Bench of the Tribunal had been taken a consistent view that the interest income earned by the co-operative society on the investments made with the schedule banks/co-operative banks/nationalized banks made out of the surplus money also qualifies for exemption

M/S RAVIKIRAN CO-OPERATIVE CREDIT SOCIETY LIMITED,BELAGAVI vs. NATIONAL E - ASSESSMENT CENTRE, DELHI

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhurysl.

section 80P(2)(d) of the Act or not?. The Pune Bench of the Tribunal had been taken a consistent view that the interest income earned by the co-operative society on the investments made with the schedule banks/co-operative banks/nationalized banks made out of the surplus money also qualifies for exemption

M/S RAVIKIRAN CO-OPERATIVE CREDIT SOCIETY LIMITED,BELAGAVI vs. THE INCOME TAX OFFICER, WARD - 3, BELAGAVI

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhurysl.

section 80P(2)(d) of the Act or not?. The Pune Bench of the Tribunal had been taken a consistent view that the interest income earned by the co-operative society on the investments made with the schedule banks/co-operative banks/nationalized banks made out of the surplus money also qualifies for exemption

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

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim

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

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 Officer to examine the issue rendered the assessment erroneous and prejudicial to the interests of the revenue. Accordingly, ld. PCIT set aside the assessment order with a direction to examine the assessee‟s claim