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

28, 29, 30, 32-35]\n2. The limited object of section 80P(4) is to exclude co-operative banks that\nfunction at par with other commercial banks i.e. which lend money to members of\nthe public. Thus, if the Banking Regulation Act, 1949 is now to be seen, what is\nclear from section 3 read with section 56 is that

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

28, 29, 30, 32-351\n2. The limited object of section 80P(4) is to exclude co-operative banks that\nfunction at par with other commercial banks i.e. which lend money to members of\nthe public. Thus, if the Banking Regulation Act, 1949 is now to be seen, what is\nclear from section 3 read with section 56 is that

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

28\nof the Act, but was taxable as \"income from other sources\" under\nSection 56 of the Act, whereas for availing the exemption or 100%\ndeduction under Section 80P of the Act the income is specified in\nclauses (a) to (f) Subsection (2) of Section 80P of the Act should be its\nbusiness or operational income.\n13. What Section

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

disallowing the exemption u/s.11 invoking the provisions of section 13(1)(c) r.w.s. 13(2) of the Act. 15. There was even an expenditure incurred on account of Foreign Tour both by Mr. Vikram Chavan, Managing Trustee and Ms. Pratima Chavan, Trustee Secretary respectively amounting to Rs.3,77,238/- as observed by the ld. AO in para

INCOME TAX OFFICER WARD-1 PANDHARPUR, INCOME TAX OFFICE PANDHARPUR vs. YASHODA MAHILA NAGARI SAHAKARI PATSANSTHA , MANGALWEDHA DISTRICT SOLAPUR

28,5,34/- against which it had claimed\ndeduction under Sec.80P(2)(d) of the Act. It was observed by\nthe Pr. CIT, that the A.O while framing the assessment had\nallowed the aforesaid claim of deduction raised by the assessee.\nObserving that as cooperative banks were commercial banks and\nnot a cooperative society, therefore

JAYANT AVINASH DAVE,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 5 , PUNE

In the result, the cross appeals are partly allowed for statistical purposes and the CO is dismissed as infructuous

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.23/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Jayant Avinash Dave Vs. Dcit, Office No.801-804, 8Th Floor, Circle 5, Pune Amar Business Park, Sadanand Estates, Plot No.1, S.No.105, Baner Road, Pune – 411045 Pan: Aaqpd6875J Appellant Respondent आयकर अपीऱ सं. / Ita No.182/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Dcit, Vs. Jayant Avinash Dave Circle 5, Pune 46/2/1B, Kaka Halwai Industrial Estate, Pune Satara Road, Pune – 411009 Pan: Aaqpd6875J Appellant Respondent Cross Objection No.11/Pun/2022 (Arising Out Of Ita No.182/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Jayant Avinash Dave Vs. Dcit, Office No.801-804, 8Th Floor, Amar Circle 5, Pune Business Park, Sadanand Estates, Plot No.1, S.No.105, Baner Road, Pune – 411045 Pan: Aaqpd6875J Cross Objector Respondent & Co No.11/Pun/2022

2)(a) at Nil, unless the assessee or the previous owner paid some purchase price for acquiring such rights. In case the assessee transfers such right to manufacture etc. and also simultaneously accepts the negative covenant of non- compete, total consideration received is considered for computing capital gain u/s 45 without taking any recourse to the provisions of section 28

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE vs. JAYANT AVINASH DAVE,, PUNE

In the result, the cross appeals are partly allowed for statistical purposes and the CO is dismissed as infructuous

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.23/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Jayant Avinash Dave Vs. Dcit, Office No.801-804, 8Th Floor, Circle 5, Pune Amar Business Park, Sadanand Estates, Plot No.1, S.No.105, Baner Road, Pune – 411045 Pan: Aaqpd6875J Appellant Respondent आयकर अपीऱ सं. / Ita No.182/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Dcit, Vs. Jayant Avinash Dave Circle 5, Pune 46/2/1B, Kaka Halwai Industrial Estate, Pune Satara Road, Pune – 411009 Pan: Aaqpd6875J Appellant Respondent Cross Objection No.11/Pun/2022 (Arising Out Of Ita No.182/Pun/2019 निर्धारण वषा / Assessment Year : 2015-2016 Jayant Avinash Dave Vs. Dcit, Office No.801-804, 8Th Floor, Amar Circle 5, Pune Business Park, Sadanand Estates, Plot No.1, S.No.105, Baner Road, Pune – 411045 Pan: Aaqpd6875J Cross Objector Respondent & Co No.11/Pun/2022

2)(a) at Nil, unless the assessee or the previous owner paid some purchase price for acquiring such rights. In case the assessee transfers such right to manufacture etc. and also simultaneously accepts the negative covenant of non- compete, total consideration received is considered for computing capital gain u/s 45 without taking any recourse to the provisions of section 28

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

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

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

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

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

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

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

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

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

section 2(24)(xviii) of the Act comes into operation and the subsidy received by the assessee is to be treated as income liable to be taxed for the year under consideration. We therefore fail to find any infirmity in the order of ld.CIT(A) and the common grounds of appeal No.2 raised by the assessee for the Assessment Years

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

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

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

In the result, the appeal filed by the Revenue stands dismissed

2). Since the order of the ld. CIT(A) is based on the ratio laid down by the Hon’ble Jurisdictional High Court in the cases referred (supra), we do not find any reason to interfere with the order of the ld. CIT(A). Hence, the ground of appeal no.2 filed by the Revenue stands dismissed. 15. Ground of appeal

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE -3, NASHIK vs. WINDSOR MACHINES LTD., MUMBAI

In the result, the appeal of Revenue is partly allowed

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

section 32(2) of the Act as discussed above. 5.5 However, it is seen that in this ground of appeal, the appellant has challenged the disallowance of carry forward of unabsorbed depreciation totaling to Rs.19,89,09,661/- pertaining to AY 1997-98 to AY 2000-01, while as noted by the AO, the assessed unabsorbed depreciation pertaining

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

28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered eitherunder the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State forthe registration

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

28. Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co-operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered eitherunder the Co-operative Societies Act, 1912 or under any other law for the time being in force in any State forthe registration

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX-1,, PUNE

Bench: Shri S.S.Godara & G.D.Padmahshaliआयकरअपीलसं. / Ita No.590/Pun/2018 िनधा"रण वष" / Assessment Year: 2014-15 Eaton Technologies Private Limited, Dcit, Circle-1(2), Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No.902/Pun/2018 िनधा"रण वष" / Assessment Year: 2011-12 Eaton Technologies Private Limited, Pr.Cit-1, Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue

2) of Rule 8D of the Income-tax Rules, 1962 (“Rules”) without recording any satisfaction which is a sine qua non for making disallowance under section 14A. 10. Notwithstanding and without prejudice to the above and on the facts and circumstances of the case and in law, the CIT(A) has erred in not accepting the claim of the Appellant