SETH RAMDAS NATHUBHAI DHARMADAYA VISHWASTA NIDHI,,PUNE vs. INCOME-TAX OFFICER,(EXEMPTIONS) -1,, PUNE

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury"नधा"रण वष" / Assessment Year : 2011-12 Seth Ramdas Nathubhai Dharmadaya Vs. Ito Vishwasta Nidhi, (Exemptions)-1, C/O. Shah Khandelwal Jain & Pune Associates, Chartered Accountants, Level 3, Business Bay, Plot No.84, Wellesley Road, Near Rto, Pune 411 001 Pan : Aaatr6805N Appellant Respondent

d) of the Act. The benefit of exemption u/s 11 was denied in the case of the appellant due to violation under section 13(l)(c)/13(2) and, therefore, such partial disallowance

MAHATMA GANDHI NAGRI SAHAKARI PAT SANSTHA MYDT UDGIR,LATUR vs. INCOME TAX OFFICER- WARD 1 -LATUR, LATUR

In the result, the appeal of the assessee is allowed

disallowed the\ndeduction claimed by the assessee u/s 80P(2)(a)(i)/80P(2)(d) of the Act\namounting to Rs.3,04,88,392/- treating the same as other income'.\nAccordingly, the Ld. AO completed the assessment on 28.09.2021 u/s\n143(3) r.w.s.144B of the Act by making an addition of Rs.3,04,88,392/- as\nincome from other sources

AHMEDNAGAR ZILLA GRAMSEVAKANCHI SAHAKAR PATSANSTHA MARYADIT,AHILYANAGAR vs. PCIT, PUNE-1, PUNE

In the result, the appeal of the assessee is allowed

13,749.00/-\nB) Deduction From total Income under chapter VI-A\na) Profit form Providing Credit facility to Members U/S 80P(2)(ai) RS 31,75,810/-\nThe assesse is co-operative society registered under the Maharashtra state co-operative\nsocieties Act 1960 formed for the benefit of Gramsevak i.e employees of Grampanchayat and\nZilha Parishad Servants\nin the Ahmednagar

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

Bench: Shri R.K. Panda & Ms. Astha Chandra

disallowance of deduction claimed u/s 80P(2)(d) of the Act, to the total income of Rs.1,54,81,910/- returned by the assessee u/s 147 r.w.s. 144B of the Act vide his order dated 26.05.2023. 3. Aggrieved, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) in para 5.4 of his appellate order observed that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

Bench: Shri R.K. Panda & Ms. Astha Chandra

disallowance of deduction claimed u/s 80P(2)(d) of the Act, to the total income of Rs.1,54,81,910/- returned by the assessee u/s 147 r.w.s. 144B of the Act vide his order dated 26.05.2023. 3. Aggrieved, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) in para 5.4 of his appellate order observed that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 PUNE, PUNE vs. JANATA GRAHAK MADHYAWARTI SAHKARI SANGH MARYADIT, PUNE

In the result, the appeal of the Revenue in ITA No

Bench: Shri R.K. Panda & Ms. Astha Chandra

disallowance of deduction claimed u/s 80P(2)(d) of the Act, to the total income of Rs.1,54,81,910/- returned by the assessee u/s 147 r.w.s. 144B of the Act vide his order dated 26.05.2023. 3. Aggrieved, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) in para 5.4 of his appellate order observed that

SHETH CHIMANLAL GOVINDDAS MEMORIAL TRUST,PUNE vs. CIT(EXEMPTION), PUNE, PUNE

In the result, appeal of the assessee is dismissed

d), 13(2)(a). 13(2)(g), and 13(2)(h), as well as the\nprescribed modes of investment under Section 11(5). Therefore, the\nFAO was required to disallow

PUNE MADHYAMIK SHIKSHAK SAHKARI PATAPEDHI MARYADIT,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX,PUNE 4, PUNE

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

disallowance from the interest paid may be made. (ii) High Creditors/liabilities: Assessee has shown high liabilities in balance sheet as compared to low income/receipt declared in ITR, Genuineness of liabilities declared may be verified. (iii) Deduction from Total Income under Chapter VI-A: The assessee has claimed large deduction under chapter VI-A (excluding deduction claimed

PUNE ZILLA SAHAKARI DUDH UTPADAK SANGH MARYADIT,PUNE vs. DCIT, CIRCLE-5, PUNE, PUNE

In the result, appeal of the Assessee for A

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2194 & 2195/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Pune Zilla Sahakari Dudh V Dcit, Utpadak Sangh Maryadit, S. Circle-5, Pune. Katraj Dairy, Pune Satara Road, Katraj, Pune – 411037. Pan: Aaaap0836A Appellant/ Assessee Respondent / Revenue Assessee By Shri M.R.Bhagwat Revenue By Smt. Saumya Pandey Jain – Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 30.07.2025 Emanating From The Separate Assessment Orders Under Section 143(3) Of The Act, 1961 Dated 19.12.2019 & 19.01.2021 For The A.Y.2017-18 & 2018-19 Respectively. For The Sake Of Convenience, Both The Appeals Were Heard Together & Decided In A

section 80P(2)(d) of the Act. Accordingly, we direct the Assessing Officer to delete the addition. According, Grounds of appeal raised by the Assessee are allowed. 13. In the result, appeal of the Assessee for A.Y.2017-18 is allowed. ITA No.2195/PUN/2025 for A.Y.2018-19 13. Since we have decided the main appeal in favour of the assessee above, the same shall

PUNE ZILLA SAHAKARI DUDH UTPADAK SANGH MARYADIT,PUNE vs. DCIT, CIRCLE-5, PUNE, PUNE

In the result, appeal of the Assessee for A

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2194 & 2195/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Pune Zilla Sahakari Dudh V Dcit, Utpadak Sangh Maryadit, S. Circle-5, Pune. Katraj Dairy, Pune Satara Road, Katraj, Pune – 411037. Pan: Aaaap0836A Appellant/ Assessee Respondent / Revenue Assessee By Shri M.R.Bhagwat Revenue By Smt. Saumya Pandey Jain – Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 30.07.2025 Emanating From The Separate Assessment Orders Under Section 143(3) Of The Act, 1961 Dated 19.12.2019 & 19.01.2021 For The A.Y.2017-18 & 2018-19 Respectively. For The Sake Of Convenience, Both The Appeals Were Heard Together & Decided In A

section 80P(2)(d) of the Act. Accordingly, we direct the Assessing Officer to delete the addition. According, Grounds of appeal raised by the Assessee are allowed. 13. In the result, appeal of the Assessee for A.Y.2017-18 is allowed. ITA No.2195/PUN/2025 for A.Y.2018-19 13. Since we have decided the main appeal in favour of the assessee above, the same shall

INCOME TAX OFFICER WARD-2, AHMEDNAGAR, AHMEDNAGAR vs. KANIFNATH GRMAIN BIGAR SHETI SAHAKARI, MALDAD SANGAMNER

In the result, Revenue’s Appeal is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

13. Ground No.IV of the Revenue is as under : “iv) On the facts and the circumstances of the case and in law, the Ld. CIT(A)/NFAC erred in allowing the deduction u/s 80P(2)(d) of the Act without considering the decision of the Hon'ble High Court of Karnataka in the case of PCIT, Hubballi Vs. Totagars

INCOME TAX OFFICER WARD-2, AHMEDNAGAR, AHAMEDNAGAR vs. KANIFNATH GRMAIN BIGAR SHETI SAHAKARIPATSANSTHA MARYADIT, , MALDAD

In the result, Revenue’s Appeal is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

13. Ground No.IV of the Revenue is as under : “iv) On the facts and the circumstances of the case and in law, the Ld. CIT(A)/NFAC erred in allowing the deduction u/s 80P(2)(d) of the Act without considering the decision of the Hon'ble High Court of Karnataka in the case of PCIT, Hubballi Vs. Totagars

INCOME TAX OFFICER WARD 1 SATARA, SATARA vs. KARAD PATAN TALUKA PRATHMIK SHIKSHAK SAHAKARI SOCIETY LIMITEDTY , KARAD

In the result, Revenue’s Appeal is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2289/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Income Tax Officer, V Karad Patan Taluka Prathmik Ward-1, Satara. S Shikshak Sahakari Society Limited, 190 B Shaniwar Peth, Opp.Shivneri Lodge, Karad, Satara – 415110 Pan: Aaaak0559R Appellant / Assessee Respondent / Revenue Assessee By Shri Satish U Nade Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated

disallowed assessee’s claim for deduction u/s.80P(2) of the Act. The relevant paragraphs 4.5 to 6 of Assessment Order are reproduced here as under : 3 ITA No.2289/PUN/2025 [A] “4.5.) Further, it may be noted that the assessee for the year under consideration has claimed the deduction U's 80P of the Act to the extent of Rs. 2

AJIT NAGARI SAHAKARI PAT SANSTHA LTD,PUNE vs. DCIT, CIR-7, PUNE, PUNE

In the result, appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2318/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Ajit Nagari Sahakari Pat V Dcit, Sanstha Ltd., S Circle-7, Pune. Rashtrawadi Bhavan, Hudco Road, Saswad, Tal-Khed, Pune – 412301. Pan: Aaaaa6401E Appellant/ Assessee Respondent /Revenue Assessee By Smt Deepa Khare Revenue By Smt Neha Thakkar – (Virtual) On Rotation Duty Date Of Hearing 22/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2022-23 Dated 10.01.2025 Emanating From The Assessment Order Passed Under

disallowed deduction claimed u/S. 80P(2)(d) of the Income Tax Act and in the light of the decision of the Supreme Court with regard to the same exact assessee as the present one, namely, The Totgars Co- operative Sale Society Ltd. v. Income Tax Officer in Civil AppealNos.1622 to 1629/2010 decided by the Apex Court

MAHATMA GANDHI NAGRI SAHAKARI PAT SANSTHA MYDT UDGIR,LATUR vs. INCOME TAX OFFICER- WARD 1 -LATUR, LATUR

Bench: Shri R.K. Panda & Ms. Astha Chandra

disallowing the deduction claimed by the appellant u/s.80P(2)(a)(i) of Rs. 3,04,88,392/-. Since all are related grounds of appeal same are adjudicated combinedly as under:- (i) The appellant is a Co-operative credit society. The funds of the appellant were deposited in different Co-operative banks and earned interest income of Rs.3

DHARMAVEER SAMBHAJI NAGARI SAHAKARI PAT MARYADIT,PUNE vs. PCIT, PUNE

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Dharmaveer Sambhaji Nagari Pcit-3, Pune Sahakari Pat Maryadit Vs. A/P Manchar, Tal-Ambegaon, Dist. Pune – 410503 Pan: Aaaad5228N (Appellant) (Respondent) Assessee By : Shri Sandip Argade Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 13-01-2026 Date Of Pronouncement : 16-01-2026

13-01-2026 Date of pronouncement : 16-01-2026 O R D E R PER R.K. PANDA, V.P: This appeal filed by the assessee is directed against the order dated 13.03.2025 passed u/s 263 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Ld. PCIT, Pune-3 relating to assessment year 2020-21. 2. Although

INCOME TAX OFFICER, WARD 1(1), NASHIK, NASHIK vs. SWA ASHOKRAO BANKAR NAGARI SAHAKARI PATSANSTHA MARYADIT, NASHIK

In the result, the appeal is dismissed

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

disallowed and brought to tax accordingly.” 6. In appeal, the CIT(A) / NFAC allowed the claim of deduction made by the assessee by recording as under: “4.3 I have gone through the facts of the case. There has been a very recent Jurisdictional ITAT order, ITA No.553/PUN/2023 (Kai Fakira Jairam Patil Sahakari Patsanstha Maryadit Shahada vs ITO Ward-1, Dhule

NERE VIBHAG NAGARI SAH. PATSANSTHA MARYADIT,PUNE vs. INCOME TAX OFFICER WARD 5(4), PUNE

In the result, appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2374/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Nere Vibhag Nagari Sah. V Income Tax Officer, Patsanstha Maryadit, S Ward-5(4), Pune. 61, Mangalwar Peth, Tal – Bhor, Pune – 412206. Pan: Aacan2385C Appellant/ Assessee Respondent /Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Ajitesh Kumar Meena – Addl.Cit Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 31.07.2025 Emanating From The Assessment Order Passed Under Section 144 Of The Act, Dated 04.12.2019. The Assessee Has Raised The Following Grounds Of Appeal :

disallowed deduction claimed u/S. 80P(2)(d) of the Income Tax Act and in the light of the decision of the Supreme Court with regard to the same exact assessee as the present one, namely, The Totgars Co- operative Sale Society Ltd. v. Income Tax Officer in Civil AppealNos.1622 to 1629/2010 decided by the Apex Court

MANGILAL LAKAHJI CHOWDHARY,,PUNE vs. INCOME-TAX OFFICER, WARD - 3(1),, PUNE

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Dr.Dipak P.Ripoteआयकरअपीलसं. / Ita No.2791/Pun/2017 िनधा"रण वष" / Assessment Year: 2013-14

disallowance of Rs.1,20,000/- in these peculiar circumstances. 4. The assessee does not press for his third substantive ground of challenging section 41(1) - cession of liability addition of Rs.50,000/- representing deposits received from M/s. Shubha Associates keeping in mind the smallness of the amount. Rejected accordingly. 5. Lastly comes the long term capital gains addition issue