ITO, PUNE vs. THEGOVERNMENTSERVENTSMAHARASTRACO-OP CREDIT SOCIETY LIMITED PUNE, PUNE

In the result, both the appeals filed by the Revenue are\ndismissed

disallowance made by the AO was deleted, but the assessee was directed to furnish details regarding transactions with different categories of members before the AO for verification.", "result": "Dismissed", "sections": [ "250", "143(2)", "142(1)", "80P", "80P(2)(a)(i)", "270A", "194A", "194A(3)(v

ITO, PUNE vs. THE GOVERNMENT SERVENTS MAHARASHTRA CO-OP CREDIT SOCIETY LIMITED PUNE, PUNE

In the result, both the appeals filed by the Revenue are\ndismissed

disallowance by the AO was deleted, subject to verification of details.", "result": "Dismissed", "sections": [ "250", "143(2)", "142(1)", "80P", "80P(2)(a)(i)", "270A", "194A", "194A(3)(v

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

NASHIK DISTRICT PRIMARY TEACHERS CO-OP CREDIT SOCIETY LTD,NASHIK vs. ITO WARD 1(1), NASHIK

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

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

194A(3)(v) has been so amended, Section 8OP(2)(d) has not been amended to include co-operative banks explicitly viii) Provisions relating to exemption and deduction need to be strictly construed and no liberal interpretation on intendment can be inferred in such provisions. An interest income not allowed as deduction u/s 80P(2)(a) cannot be allowed

NASHIK DISTRICT PRIMARY TEACHERS CO-OP CREDIT SOCIETY LTD,NASHIK vs. ITO WARD 1(1), NASHIK

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

194A(3)(v) has been so amended, Section 8OP(2)(d) has\nnot been amended to include co-operative banks explicitly\nviii) Provisions relating to exemption and deduction need to be strictly\nconstrued and no liberal interpretation on intendment can be inferred in\nsuch provisions. An interest income not allowed as deduction u/s 80P(2)(a)\ncannot be allowed

TOKAI SAHAKARI SAKHAR KARKHANA LTD,HINGOLI vs. INCOME TAX OFFICER, WARD-(1), JALNA, JALNA

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Shri G.D.Padmahshaliआयकर अपील सं. / Ita No.571/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Tokai Sahakari Sakhar Karkhana The Income Tax Officer, Ltd., Vs Ward-1, Jalna. Villag Kurunda, Taluka Basmath . District, Hingoli – 431512. Pan: Aaat6997Q Appellant / Assessee Respondent / Revenue Assessee By Shri Anand Partani – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 16/01/2024 Date Of Pronouncement 16/01/2024

section 194A(3)(V) relating payments to members made by a co-operative society; respectively. We accordingly reject the Revenue’s vehement contention in very terms. The assessee succeeds in its instant 3rd to 5th substantive grounds. 7. Lastly comes the assessee’s sixth substantive ground seeking to delete interest expenses disallowance

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

In the result, the appeal of the assessee is allowed

194A of the Act\nalso makes the legislative intent clear that the Co-operative Banks are not\nthat species of genus co-operative society, which would be entitled to\nexemption or deduction under the special provisions of Chapter VIA in the\nform of Section 80P of the Act.\n7.3 In the light of above legal position, it is amply clear

M/S KOLTE PATIL DEVELOPERS LTD,PUNE vs. DCIT,CIRCLE-7, PUNE, PUNE

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15

disallowing entire expenditure is not justified. 3. The first issue raised in the grounds of appeal No.1 and 2 relates to the order of the CIT(A) / NFAC in confirming the addition of Rs.14,70,250/- out of the addition of Rs.25,02,250/- made by the Assessing Officer u/s 43CA of the Act. 4. Facts of the case

VIJAY VYANKATRAO MANE,SADASHIV PEATH vs. ADDITIONAL COMMISSIONER , ADDL/JCIT(A)- CHANDIGARH

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2015-16

194A of the Act. disallowance is required to be made as per section 40(a)(ia) of the Act. Therefore, the assessing Officer is directed to allow the interest expenditure after making verification of applicability of TDS provisions on interest and after making disallowance under section 40(a)(ia) of the Act, if required. Accordingly, the Ground

THE SATARA ZILLA KRISHI BANK KARMACHARI SAHAKARI PATSANSTHA LTD,SATARA vs. ACIT, SATARA, CIR-SATARA, SATARA

In the result, the appeal of the assessee is allowed for statistical\npurposes

194A of the Act\nalso makes the legislative intent clear that the Co-operative Banks are not\nthat specie of genus co-operative society, which would be entitled to\nexemption or deduction under the special provisions of Chapter VIA in the\nform of Section 80P of the Act. Co-operative banks also accept deposit from\nboth members and non-members

THE SATARA ZILLA KRISHI BANK KARMACHARI SAHAKARI PATSANSTHA LTD,SATARA vs. ACIT, SATARA, CIR-SATARA, SATARA

In the result, the appeal of the assessee is allowed for statistical\npurposes

194A of the Act\nalso makes the legislative intent clear that the Co-operative Banks are not\nthat specie of genus co-operative society, which would be entitled to\nexemption or deduction under the special provisions of Chapter VIA in the\nform of Section 80P of the Act. Co-operative banks also accept deposit from\nboth members and non-members

R&DE (ENGRS) EMPLOYEES CO-OP. CREDIT SOCIETY,PUNE vs. ITO, WARD 7(3), PUNE, PUNE

In the result, the appeal of the assessee is allowed

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

194A of the Act also makes the legislative intent clear that the Co-operative Banks are not that specie of genus co-operative society, which would be entitled to exemption or deduction under the special provisions of Chapter VIA in the form of section 80P of the Act. (Paragarph 15 of the Judgment). If the legislative intent is so clear

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

v) of the Act excluding the Со-\noperative Banks from the definition of \"Co-operative Society\" by\nFinance Act, 2015 and requiring them to deduct income tax at source\nunder Section 194A of the Act also makes the legislative intent clear\nthat the Co-operative Banks are not that specie of genus co-operative\nsociety, which would be entitled

INCOME TAX OFFICER WARD-2, AHMEDNAGAR., AHMEDNAGAR vs. KANHUR PATHAR MULTI STATE CO-OPERATIVE CREDIT SOCIETY MARYADIT , KANHUR, KANHUR DIST. AHMEDNAGAR

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

section 194A(3)(v) have excluded Co- Operative Bank from Co-operative society to deduct TDS u/s194A on interest paid to member thereof. Thus, the legislative intent is to distinguish co-operative banks from co- operative societies for the purpose of benefits u/s 80P as held by Hon’ble Karnataka High Court in case of PCIT vs. Totagars Co- operative

INCOME TAX OFFICER WARD-2, AHMEDNAGAR., AAYAKAR, BHAVAN, BEHIND NATRAJ HOTEL, AURANGABAD ROAD, AHMEDNAGAR vs. KANHUR PATHAR MULTI STATE CO-OPERATIVE CREDIT SOCIETY MARYADIT KANHUR, KANHUR DIST. AHMEDNAGAR

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

section 194A(3)(v) have excluded Co- Operative Bank from Co-operative society to deduct TDS u/s194A on interest paid to member thereof. Thus, the legislative intent is to distinguish co-operative banks from co- operative societies for the purpose of benefits u/s 80P as held by Hon’ble Karnataka High Court in case of PCIT vs. Totagars Co- operative

GOVIND MILK AND MILK PRODUCTS PVT. LTD. ,PHALTAN vs. INCOME TAX OFFICER, WARD-3, SATARA, SATARA

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.848/Pun/2023 िनधा"रण वष" / Assessment Year : 2016-17 Govind Milk & Milk Products The Income Tax Pvt. Ltd., V Officer, Ward-3, Ganesh Sheri, Pune Pandharpur S Satara. Road, At Post Kolki, Phaltan, Satara, Maharashtra. Pan: Aaacg7588A Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri R.Y.Balawade – Addl.Cit Date Of Hearing 13/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 25.05.2023. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal : “1. The Ld Cit(A) Erred In Passing Her Order Ex-Parte Without Allowing Appellant Reasonable Opportunity Of Being Heard. 2. The Ld Cit(A) Erred In Upholding The Disallowance Of Rs.43,51,377/- Under Section 40(A)(Ia) Made By The Ld Ao Without Govind Milk & Milk Products Pvt. Ltd., [A]

V Officer, Ward-3, Ganesh Sheri, Pune Pandharpur s Satara. Road, At Post Kolki, Phaltan, Satara, Maharashtra. PAN: AAACG7588A Appellant/ Assessee Respondent /Revenue Assessee by None. Revenue by Shri R.Y.Balawade – Addl.CIT Date of hearing 13/03/2024 Date of pronouncement 26/03/2024 आदेश/ ORDER PER DR. DIPAK P. RIPOTE, AM: This appeal filed by the assessee against the order of Ld.Commissioner of Income

THE RATNAKAR BANK EMPLOYEES CO OP CREDIT SOCIETY LTD KOLHAPUR,KOLHAPUR vs. INCOME TAX OFFICER, KOLHAPUR

In the result, appeal of the assessee is allowed

Bench: Or At The Time Of Hearing.”

194A  ITAT ORDER NIPHAD NAGARI SAHAKARI VS DEPARTMENT OF INCOME TAX ITA_1336_OFJ2011  RENA SAHAKARI SAKHAR KARKHANA  ITAT OF RATNKARA BANK EMPLOYEES CO-OP CREDIT SOCIETY AY-2022-23-SYNOPSIS-SUBMISSION 2 ITA No.1725/PUN/2025 [A] Submission of ld.DR : 3. Ld.Departmental Representative(ld.DR) for the Revenue relied on the order of the ld.CIT(A). Findings & Analysis : 4. We have heard