ALNESH AKIL SOMJI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

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

section 57(iii) of the IT Act, deduction of interest paid shall be allowed as deduction only if it is laid out wholly and exclusively for the purpose of making or earning such income. As is evident from the above table, the assessee has received interest @21% on the amount of loans given to M/s Gagan I Land Township

ALNESH MOHAMADAKIL SOMJI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

14 (SC) where interpreting the corresponding\nprovision in section 12(2) of the Indian IT Act, 1922, which was ipsissima verba in\nthe same terms as Section 57(1), Bose J speaking on behalf of the Court, observed:\n“It is not necessary to show that the expenditure was a profitable one or that in\nfact any profit was earned

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

In the result, the appeal of the assessee is allowed

iii). Deduction from Total Income\nunder Chapter VI-A.\n2. Accordingly notice u/s 143(2) was issued and duly served upon the\nassessee. Subsequently notices u/s 142(1) of the Income Tax Act 1961 was\nissued to the assessee asking certain details which were covered in the\nscrutiny reason. The assessee had given reply to the notices by online\nsubmission

DY. COMMISSIONER OF INCOME TAX, SATARA CIRCLE, SATARA, SATARA vs. SHRI SIDDHANATH NAGARI SAHAKARI PATSANSTHA MARYA DAHIWADI, TAL. MAN SATARA

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

disallowing deduction u/s\n80P(2)(d) is concerned, there are various other High Court judgements which\nhave allowed the deduction under section 80P(2)(d) in respect of interest\n/dividend received by a co-operative society from its investments in another co-\noperative society. He relied on the following decisions :\na. Hon'ble Gujarat High Court in case of Surat

DY. COMMISSIONER OF INCOME TAX, SATARA CIRCLE, SATARA, SATARA vs. SHRI SIDDHANATH NAGARI SAHAKARI PATSANSTHA MARYA DAHIWADI, MAN,SATARA

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

disallowing deduction u/s\n80P(2)(d) is concerned, there are various other High Court judgements which\nhave allowed the deduction under section 80P(2)(d) in respect of interest\n/dividend received by a co-operative society from its investments in another co-\noperative society. He relied on the following decisions :\na. Hon'ble Gujarat High Court in case of Surat

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

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

AURANGABAD DIVISION LIFE INSURANCE EMPLOYEES CO-OP CREDIT SOCIETY LTD,AURANBAD vs. ITO, WARD-1(1), AURANGABAD, AURANGABAD

In the result, appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3175/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Aurangabad Divison Life V The Income Tax Officer, Insurance Employees Co-Op S Ward-1(1), Aurangabad. Credit Society Ltd., 11, Jeevan Prakash, Lic Office Building Adalat Road, Kranti Chowk, Aurangabad -431005 Pan: Aaaaa2245A Appellant/ Assessee Respondent /Revenue Assessee By Ca Payal Rathi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 09/02/2026 Date Of Pronouncement 10/02/2026 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.2020-21 Dated 24.09.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Income Tax Act, 1961

disallowed by Assessing Officer. 3 ITA No.3175/PUN/2025 [A] 3.1 Thus, the issue before us is whether Assessee Co-operative Credit Society is eligible for deduction u/s.80P(2)(a)(i) of the Act, on the Interest Income earned from depositing excess funds. 3.2 The Hon’ble Supreme Court in the case of Bihar State Co- operative Bank

ACIT, CIRCLE-5, PUNE, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

14. The assessee in the instant case has made out its case that it falls under proviso to Explanation 10 to section 43(1) of the Act and has done the treatment accordingly apportioning the subsidy on the total fixed assets and after reducing it from fixed assets has claimed depreciation. 15. Now at this juncture, we would like

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

14. The assessee in the instant case has made out its case that it falls under proviso to Explanation 10 to section 43(1) of the Act and has done the treatment accordingly apportioning the subsidy on the total fixed assets and after reducing it from fixed assets has claimed depreciation. 15. Now at this juncture, we would like

DY. COMMISSIONER OF INCOME-TAX, CIRCLE-5, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD., PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

14. The assessee in the instant case has made out its case that it falls under proviso to Explanation 10 to section 43(1) of the Act and has done the treatment accordingly apportioning the subsidy on the total fixed assets and after reducing it from fixed assets has claimed depreciation. 15. Now at this juncture, we would like

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD.,PUNE vs. ACIT, CIRCLE-5, PUNE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

14. The assessee in the instant case has made out its case that it falls under proviso to Explanation 10 to section 43(1) of the Act and has done the treatment accordingly apportioning the subsidy on the total fixed assets and after reducing it from fixed assets has claimed depreciation. 15. Now at this juncture, we would like

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

14. The assessee in the instant case has made out its case that it falls under proviso to Explanation 10 to section 43(1) of the Act and has done the treatment accordingly apportioning the subsidy on the total fixed assets and after reducing it from fixed assets has claimed depreciation. 15. Now at this juncture, we would like

VIRENDRA SINGH SAINI,HARYANA vs. ASST. DIRECTOR OF INCOME TAX, CPC, BANGALORE, BENGALORE

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1483/Pun/2024 "नधा"रण वष" / Assessment Year : 2019-20

iii) having details of due date for payment and the actual date of payment indicate about `disallowance of expenditure’ if the assessee does not make suo motu disallowance in computing total income. Right now, there is no case of `increase in income’ because the AO did not make adjustment for non-offering of income of the `Sums received from employees

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 PUNE, PUNE vs. KOLTE PATIL INTEGRATED TOWNSHIPS LIMITED, PUNE

In the result, both the appeals filed by the Revenue are dismissed

2) He submitted that clauses (i) and (ii) of above definition refers to fixed asset\nwhich is not the case of the assessee. Clause (iii) refers to inventories that require\na period of 12 months or more to bring them to a saleable condition. Referring to\nclause 8 of ICDS, he submitted that in case of inventory, the interest

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

III) That this Court in Kerala State Cooperative Marketing Federation Ltd. (supra) has construedsection 80P widely and liberally, holding that if a society were to avail of several heads ofdeduction, and if it fell within any one head of deduction, it would be free from tax notwithstandingthat the conditions of another head of deduction are not satisfied;(IV) This

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

III) That this Court in Kerala State Cooperative Marketing Federation Ltd. (supra) has construedsection 80P widely and liberally, holding that if a society were to avail of several heads ofdeduction, and if it fell within any one head of deduction, it would be free from tax notwithstandingthat the conditions of another head of deduction are not satisfied;(IV) This

HAVELI TALUKA VEEJ KAMGAR SAHAKARI PATHSANSTHA MARYADIT,PUNE vs. INCOME TAX OFFICER WARD 6 (1) PUNE, PMT BUILDING, SWARGATE

In the result, the appeal of the assessee is allowed

disallowing the assessee's sec.80P\ndeduction claim representing interest income from co-operative\nsociety(ies)/bank(s)/nationalized bank(s) involving varying sums; as\nthe case may be. It is in this factual backdrop that we first of all note\nthat the tribunal in The Rena Sahakari Sakhar Karkhana Ltd. vs.\nPCIT's case has already rejected the Revenue

DCIT EXMP CIRCLE PUNE, SWARGATE PMT BLDG vs. ASHIRWAD CHARITABLE TRUST, MUMBAI

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.224 & 225/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Dcit (Exemptions) Circle, Vs. Ashirwad Charitable Pune. Trust, 402, Pascal Martin Road, Regent Chambers, Nariman Point, Mumbai- 400021. Pan : Aabta4479Q Appellant Respondent Revenue By : Shri Ramnath P. Murkunde Assessee By : Shri Raja B. Singh & Mohd. Obaid Ansari Date Of Hearing : 18.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 06.12.2023 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15 Respectively. 2. Since The Facts Are Identical & Both The Above Captioned Appeals Were Heard Together, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal In Ita No.224/Pun/2024 For Adjudication.

disallowing the deduction of income accumulated/set apart under section 11(2) of the Act is found to be untenable and the Ld. AO is directed to delete the same accordingly. Further, the Ld. AO has made addition by adding Rs.4,93,72,616/- as the assessee trust did not provide list of corpus donors and the genuineness of the donors