INCOME-TAX OFFICER vs. KESHAVSMURTI NAGARI SAHAKARI PATPEDHI LTD.,, RAIGAD

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.936/Pun/2015 यििाारण वषा / Assessment Year : 2010-11 The Income Tax Officer, अऩीऱाथी/Appellant Ward 5, Panvel …. Vs. Keshavsmurti Nagari Sahakari Patpedhi Ltd., Shop No.1G/F, Anpurna Niwas, Shivaji Road, Tal – Panvel, …. प्रत्यथी / Respondent Dist – Raigad – 410206 Pan: Aaaak7390L प्रत्याक्षेप सं./Co No.30/Pun/2017 यििाारण वषा / Assessment Year : 2010-11 (Out Of Ita No.936/Pun/2015) Keshavsmurti Nagari Sahakari Patpedhi Ltd., Shop No.1G/F, Anpurna Niwas, Shivaji Road, Tal – Panvel, … प्रत्याक्षेऩक/ Cross Objector Dist – Raigad – 410206 Pan: Aaaak7390L Vs. The Income Tax Officer, …. प्रत्यथी / Respondent Ward 5, Panvel

section 80P(2)(d) of the Act and no amount was assessed in the hands of the assessee except the dividend received from UTI Mutual Funds and Sundaram Finance of Rs.87,087/- and Rs.88,519/-. The assessee has placed on record its balance sheet along with Profit & Loss account for the year under consideration at pages

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

section 80P(2)(a)(i) in respect of interest income earned by a\ncooperative society from the cooperative banks/commercial banks, there is a\ncleavage of judicial opinion among several High Courts on the issue of\neligibility of this kind of income for exemption u/s.80P(2)(a)(i) of the Act. The\nHon'ble Punjab & Haryana High Court

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

section 80P(2)(a)(i) in respect of interest income earned by a cooperative society from the cooperative banks/commercial banks, there is a cleavage of judicial opinion among several High Courts on the issue of eligibility of this kind of income for exemption u/s. 80P(2)(a)(i) of the Act. The Hon’ble Punjab & Haryana High Court

KAI FAKIRA JAIRAM PATIL SAHAKARI PATSANSTHA MARYADIT SHAHADA,NANDURBAR vs. ITO, WARD-1, DHULE, DHULE

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

section 80P(2)(d) in respect of interest income earned by a cooperative society from the cooperative bank. There is a cleavage of judicial opinion among several High Courts on the issue of eligibility of this kind of income for exemption u/s. 80P(2)(a)(i) of the Act. The Hon’ble Punjab & Haryana High Court in the case

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

section 80P(2)(a)(i) in respect of interest income earned by a\ncooperative society from the cooperative banks/commercial banks, there is a\ncleavage of judicial opinion among several High Courts on the issue of eligibility\nof this kind of income for exemption u/s.80P(2)(a)(i) of the Act. The Hon'ble\nPunjab & Haryana High Court

INCOME TAX OFFICER, WARD-1(1), NASHIK, NASHIK vs. MICO EMPLOYEES CREDIT COOP SOCIETY LTD., NASHIK

In the result, the appeal of the Revenue is dismissed

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

section 80P(2)(a)(i), other issues raised by the appellant have become redundant.” 6. Dissatisfied, the Revenue is in appeal before the Tribunal and all the grounds of appeal relate thereto. 7. The Ld. AR reiterated the same submissions made before the lower authorities in support of its claim of deduction of interest income u/s 80P(2

MOHOL NAGARI SAHAKARI PATPURVATHA SANSTHA MARYADIT,SOLAPUR vs. ITO WARD 2, PANDHARPUR

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

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

section 80P(2) of the Act on interest earned by them from Fixed Deposits kept with another cooperative Banks. ITAT Pune in the case of Kundalika Nagari Sahakari Patsanstha Maryadit178 TTJ 381 (Pune - Trib.) has held as under : Quote, “ The assessee has further furnished the break-up of FDs with different co-operative banks at pages 57 to 68

INCOME TAX OFFICER WARD-2 PANDHARPUR, PANDHARPUR vs. MOHOL NAGARI SAHAKARI PATPURAVATHA SASTHA MARYADIT, MOHOL

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

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

section 80P(2) of the Act on interest earned by them from Fixed Deposits kept with another cooperative Banks. ITAT Pune in the case of Kundalika Nagari Sahakari Patsanstha Maryadit178 TTJ 381 (Pune - Trib.) has held as under : Quote, “ The assessee has further furnished the break-up of FDs with different co-operative banks at pages 57 to 68

INCOME TAX OFFICER WARD-2 PANDHARPUR, PANDHARPUR vs. MOHOL NAGARI SAHAKARI PATPURAVATHA SANSTHA MARYADIT, MOHOL

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

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

section 80P(2) of the Act on interest earned by them from Fixed Deposits kept with another cooperative Banks. ITAT Pune in the case of Kundalika Nagari Sahakari Patsanstha Maryadit178 TTJ 381 (Pune - Trib.) has held as under : Quote, “ The assessee has further furnished the break-up of FDs with different co-operative banks at pages 57 to 68

INCOME TAX OFFICER WARD-2 PANDHARPUR, PANDHARPUR vs. MOHOL NAGARI SAHAKARI PATPURVATHA SANSTHA MARYADIT , MOHOL

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

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

section 80P(2) of the Act on interest earned by them from Fixed Deposits kept with another cooperative Banks. ITAT Pune in the case of Kundalika Nagari Sahakari Patsanstha Maryadit178 TTJ 381 (Pune - Trib.) has held as under : Quote, “ The assessee has further furnished the break-up of FDs with different co-operative banks at pages 57 to 68

INCOME TAX OFFICER WARD-2 PANDHARPUR, PANDHARPUR vs. MOHOL NAGARI SAHAKARI PATPURVAGHA SANSTHA MARYADIT, MOHOL

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

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

section 80P(2) of the Act on interest earned by them from Fixed Deposits kept with another cooperative Banks. ITAT Pune in the case of Kundalika Nagari Sahakari Patsanstha Maryadit178 TTJ 381 (Pune - Trib.) has held as under : Quote, “ The assessee has further furnished the break-up of FDs with different co-operative banks at pages 57 to 68

MOHOL NAGARI SAHAKARI PATPURVATHA SANSTHA MARYADIT,SOLAPUR vs. ITO WARD 2, PANDHARPUR

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

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

section 80P(2) of the Act on interest earned by them from Fixed Deposits kept with another cooperative Banks. ITAT Pune in the case of Kundalika Nagari Sahakari Patsanstha Maryadit178 TTJ 381 (Pune - Trib.) has held as under : Quote, “ The assessee has further furnished the break-up of FDs with different co-operative banks at pages 57 to 68

SHREE TULJABHAVANI NAGARI SAHAKARI PAT SANSTHA MARYADIT,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX -5 , PUNE, PUNE

In the result, appeal of the Assessee is allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.254/Pun/2020 िनधा"रणवष" /Assessment Year: 2014-15 Shree Tuljabhavani Nagari The Principal Commissioner Sahakari Pat Sanstha Maryadit, Vs Of Income Tax - 5, Pune. 17/04, 103, Shri Tuljibhavani Plaza Mangalnagar, Wakad Road, Thergaon, Pune. Pan: Aadas 9902 P Appellant/ Assessee Respondent/ Revenue Assessee By None. Revenue By Shri Arvind Desai – Dr Date Of Hearing 16/06/2022 Date Of Pronouncement 28/07/2022 आदेश/ Order Per Dr.Dipak P.Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Pr.Commissioner Of Income-Tax-5, Pune’S, Order Dated 08.01.2019For The Assessment Year 2014-15, Involving Proceedings Under Section 263(1) Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal: “1. Pr.Commissioner Of Income Tax Has Erred In Passing The Order Which Is Without Jurisdiction & Bad In Law. Same May Please Be Cancelled. 2. Pr.Cit Has Erred In Alleging That Order U/S 143(3) Passed By Assessing Officer Is Erroneous In So Far As It Is Prejudicial To The Interest Of Revenue. Appellant Prays To Cancel The Same.

section 80P(2), which provides that: '(a) in the case of a cooperative society engaged in— (i) carrying on the business of banking or providing credit facilities to its members …., the whole of the amount of profits and gains of business attributable to any one or more of such activities' shall be allowed as deduction. The assessee is admittedly

SHIRALA TALUKA SAHAKARI DUDH UTPADAK & PURAVATHA SANSTHA LTD,,SANGLI vs. INCOME-TAX OFFICER, WARD - 2(1),, SANGLI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

section.” 3. During the course of assessment proceedings, AO on perusing the details furnished by the assessee noticed that assessee had sold milk worth Rs.19,24,82,650/- which included sales of Rs.10,86,33,592/- made to persons other than Federal Society, the Government or local authority or a Government company as specified u/s 80P(2

INCOME TAX OFFICER , INCOME TAX OFFICE PANDHARPUR vs. DHANSHREE MAHILA GRAMIN BIGARSHETI SAHAKARI PAT SANSTHA LTD, MANGALWEDHA

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

68) (ii) Karnataka High Court in Totgars Co-operative Sale Society (2017, 395 ITR 611) (iii) Gujarat High Court in State Bank of India (2016, 389 ITR 578) (iv) Punjab & Haryana High Court in Punjab State Co-op Development Bank (2016, 389 ITR 607) all of which have held that Interest income from Fixed Deposits was to be assessed

SHREE SANT SAVTA GRAMIN BIGAR SETI SAHAKARI PATHSANSTA MARAYADIT,NASHIK vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

In the result, appeal of the Assessee is partly allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1625/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Shree Sant Savta Gramin Bigar V Assessment Unit, Seti Sahakari Pathsanstha S. Income Tax Department, Maryadit, Delhi. Pimpalgaon, Niphad, Nashik – 422209. Pan: Aacas4098M Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Dayanand Jawalikar – Addl.Cit Date Of Hearing 14/10/2025 Date Of Pronouncement 31/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2017-18, Dated 27.11.2024 Emanating From Assessment Order U/S.143(3) Of The I.T.Act, Dated 15.12.2019. The Assessee Has Raised Following Grounds Of Appeal :

80P(2)(d) of the IT Act was not justified. 3. The Appellate craves the right to add, amend, modify, alter, revise, substitute, delete any or all grounds of the appeal, if deemed necessary at the time of hearing of the appeal.” Delay : 1.1 There is a delay of 157 days in filing appeal before this Tribunal. We have perused

TALEGAON NAGARI SAHAKARI PATSANSTHA LIMITED,PUNE vs. INCOME TAX OFFICER WARD-9(3), PUNE, PUNE

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

Bench: Shri Inturi Rama Rao & Ms. Astha Chandraआयकर अपील सं. / Ita No.743/Pun/2024 "नधा"रण वष" Assessment Year : 2020-21 Talegaon Nagari Sahakari Vs. Ito, Ward-9(3), Patsanstha Limited, Pune Bajar Peth, Talegaon Dabhade, Tal. Maval, Dist. Pune 410506 Maharashtra Pan : Aabat3160G Appellant Respondent

68,351/- earned on FDs with other co-operative banks holding that the said interest does not qualify for deduction. 3. Being aggrieved, an appeal was filed before the NFAC, who vide impugned order confirmed the action of the Assessing Officer placing reliance on the decision of the Hon’ble Karnataka High Court in the case of Totgars Co.op Sale

LEKHAKOSH KARMACHARI SAHAKARI PATPEDHI SANSTHA MARYADIT,PUNE vs. PR. CIT, PUNE-4, PUNE

In the result, the appeal of the assessee is allowed

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

section 80P(2)(a)(i), the Society is required to substantiate the principle of mutuality with respect to the loans taken from members to loan advanced/ investment made by it. To come to a conclusive discussion, the AO should have verified whether the loans/ deposit taken are given back to the members as loans/ advances or not. The assessment