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

vi) The amendment of Section 194A(3)(v) excluding co-operative banks from the definition of co-operative society by Finance Act 2015, makes legislative intent clear that co-operative banks treated differently from that of co-operative society, vii) While section 194A(3)(v) has been so amended, Section 8OP(2)(d) has not been amended

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

VI. During the assessment proceeding various notices were\nissued and served to the assessee. But the assessee failed to comply with\nthese notices. Therefore, the AO completed the assessment proceeding u/s\n144, assessing the income at Rs.2,59,57,890/- by disallowing the\ndeduction claimed u/s 80P of the Act. Aggrieved by the above order of the\nAO, the appellant

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

VI-A". During the course of assessment proceedings, the Ld. Assessing Officer (“AO”) made detailed enquiry about the assessee’s claim of deduction u/s 80P of the Act. In response to the same, the assessee submitted all the relevant details. After considering the submissions of the assessee, the Ld. AO allowed the deduction u/s 80P

AJINKYA MADHYAMIK SHIKSHAK SEVAK SAH. PATSANSTHA, MARYADIT,SATARA vs. INCOME TAX OFFICER, WARD-2, SATARA, SATARA

In the result, the appeal of the assessee is allowed

68 taxтапп.com 298 (Kerala),\nthe Kerala High Court held that a return filed by assessee\nbeyond period stipulated under section 139(1) or 139(4) or\nunder section 142(1) or section 148 can also be accepted and\nacted upon for entertaining claim raised under section 80P\nprovided further proceedings in relation to such assessments

WILDERNEST BETTER LIVING & MAINTENANCE CO-OPERATIVE SOCIETY LIMITED,PUNE vs. INCOME TAX OFFICER, WARD 6(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.856/Pun/2025 िनधा"रण वष" / Assessment Year: 2020-21 Wildernest Better Living V The Income Tax Officer, Maintenance Co-Operative S Ward-6(1), Pune. Society Limited, Plot No.58, 59 & 60, Woldernest Society, Khadakwasla, Taluka Haveli, Pune – 411024. Maharashtra. Pan: Appellant/ Assessee Respondent / Revenue Assessee By Shri Arpit Dnyandeo Dambhare & Shri Deepak Sasar – Ca’S Revenue By Shri Madhan Thirmanpalli – Addl.Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 23/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Directed Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal), Panaji Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2021-22 Dated

68[or increase in income] indicated in the audit report but not taken into account in computing the total income in the return; (v) disallowance of deduction claimed under 69[section 10AA or under any of the provisions of Chapter VI-A under the heading "C.—Deductions in respect of certain incomes", if] the return is furnished beyond

SOLAPUR DIST M S K SAMITI H MASTER T AND N T PATH MYDT PANDHARPUR,PANDHARPUR vs. ITO, WARD 2, PANDHARPUR

In the result appeal of the assessee is dismissed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.804/Pun/2023 िनधा"रण वष" / Assessment Year : 2017-18 Solapur Dist M S K Samiti H The Income Tax Officer, Master T & N T Path V Ward-2, Pandharapur. Mydtpandharpur, S 3980, Station Road, Pandharpur. Maharashtra – 413304. Pan: Aanas9890E Appellant/ Assessee Respondent /Revenue Assessee By None Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 15/02/2024 Date Of Pronouncement 08/03/2024 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(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 11.05.2023 Emanating From Assessment Order Dated 30.07.2019Passed Under Section 144 R.W.S 144A Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Assessee Was In Presumption That Co Operative Societies Income Is Exempt Under 80P Generally Maximum Co Solapur Dist M S K Samiti H Master T & N T Path Mydt Pandharpur [A]

VI A under the heading "C.-Deduction in respect of certain incomes", no deduction would be allowed to him under the said provision. In plain terms, this Sub Section (5) of Section 80A of the Act imposes an additional condition for claim of deduction in relation to income under any of the provisions mentioned therein. Apart from

MAHARASHTRA RAJYA PATHYAPUSTAK MANDAL KARMACHARI SAHAKARI PAT SANSTHA MARYADIT,PUNE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX -2, PUNE

The appeal of the assessee stands ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 733/Pun/2023 निर्धारण वषा / Assessment Year : 2017-18 Maharashtra Rajya Pathyapustak Mandal Karmachari Sahakari Pat Sanstha Maryadit, Bal Bharati, Senapati Bapat Rd., Pune – 411 004 Pan: Aaaam2009A . . . . . . . अपऩलधर्थी / Appellant बिधम / V/S Pr. Commissioner Of Income Tax -2 Pune . . . . . . प्रत्यर्थी / Respondent द्वधरध / Appearances Assessee By : Mrs. J.R. Chandekar Revenue By : Shri Keyur Patel सुनवाई की तारीख / Date Of Conclusive Hearing : 25/09/2023 घोषणा की तारीख / Date Of Pronouncement : 26/09/2023 आदेश / Order Per G. D. Padmahshali, Am; This Appeal Of The Assessee For Assessment Year 2017-18 [For Short ‘Ay’] Is Assailed Against Revisionary Order Of Pr. Commissioner Of Income Tax-2, [For Short ‘Pcit’] Dt. 21/03/2022 Passed U/S 263 Of The Income-Tax Act, 1961 [For Short ‘The Act’], Which Ascended Out Of Assessment Order Dt. 24/12/2019 Passed U/S 143(3) By The Income Tax Officer, Ward 3(5), Pune [For Short ‘Ao’].

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the Ld. PCIT on due consideration of explanation filed

INDRAPRASTHA NAGARI SAHAKARI PATSANSTHA LTD.,,SANGLI vs. INCOME-TAX OFFICER, WARD -5,, SANGLI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.184/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Indraprastha Nagari Sahakari Vs. Ito, Ward-5, Sangli. Patsanstha Ltd., Islampur, Walwa, Sangli- 415409. Pan : Aaaai0626B Appellant Respondent Assessee By : Shri Sarang Gudhate Revenue By : Shri Uma Shankar Prasad Date Of Hearing : 21.11.2024 Date Of Pronouncement : 30.01.2025 आदेश / Order Per Vinay Bhamore, Jm: It Is A Recalled Matter. This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.03.2022 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Modified Grounds Of Appeal :- “Ground No. 1: Under The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) / Nfac Is Erred In Disallowing Deduction U/S 80P Of Rs. 65,81,336/-.

VI-A. Notices u/s 143(2) and 142(1) respectively were issued along with questionnaire. After considering the submission of the assessee, the assessment was completed by determining the total income at Rs.4,23,26,118/- as against the income returned by the assessee at Rs.Nil. The above assessed income includes addition of 3 Rs.65,81,336/- on account

THE MAHATMA SAHAKARI GRIHA RACHANA SANSTHA MARYADIT,PUNE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-2, PUNE, PUNE

In the result, appeals of the assessees are allowed

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.The Mahatma Sahakari Griha Vs Pr.Cit-2, Pune. Rachana Sanstha Maryadit, S.No.62 & 65, Sahakar Bhavan, Kothrud, Pune. Pan: Aabtt 5342 F Appellant Respondent Bajaj Auto Employees Co-Op Vs Ito, Ward-8, Credit Society Ltd., Bombay Pune. Pune Road, Bajaj Auto Ltd., Plot No.393/394, Sector 21, Akurdi, Pune. Pan: Aaajb 0024 D Appellant Respondent Shri Bhagwant Multistate Vs Pr.Cit-4, Pune. Credit Co-Op. Society Ltd., 739/7/17, Patil Plot, Shivaji Nagar Barshi, Solapur. Pan: Aamas 3645 L Appellant Respondent

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed

SHRI BHAGWANT MULTISTATE CREDIT CO-OPERATIVE SOCIETY LTD,SOLAPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-4, PUNE, PUNE

In the result, appeals of the assessees are allowed

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.The Mahatma Sahakari Griha Vs Pr.Cit-2, Pune. Rachana Sanstha Maryadit, S.No.62 & 65, Sahakar Bhavan, Kothrud, Pune. Pan: Aabtt 5342 F Appellant Respondent Bajaj Auto Employees Co-Op Vs Ito, Ward-8, Credit Society Ltd., Bombay Pune. Pune Road, Bajaj Auto Ltd., Plot No.393/394, Sector 21, Akurdi, Pune. Pan: Aaajb 0024 D Appellant Respondent Shri Bhagwant Multistate Vs Pr.Cit-4, Pune. Credit Co-Op. Society Ltd., 739/7/17, Patil Plot, Shivaji Nagar Barshi, Solapur. Pan: Aamas 3645 L Appellant Respondent

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed

KOLHAPUR DISTRICT CENTRAL CO- OP BANK KANISTA SEVAKANCHI SAHAKARI PAT SANSTHA LTD,KOLHAPUR vs. INCOME TAX OFFICE, WARD-2(1), KOLHAPUR, KOLHAPUR

In the result, appeals of the assessees are allowed

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.The Mahatma Sahakari Griha Vs Pr.Cit-2, Pune. Rachana Sanstha Maryadit, S.No.62 & 65, Sahakar Bhavan, Kothrud, Pune. Pan: Aabtt 5342 F Appellant Respondent Bajaj Auto Employees Co-Op Vs Ito, Ward-8, Credit Society Ltd., Bombay Pune. Pune Road, Bajaj Auto Ltd., Plot No.393/394, Sector 21, Akurdi, Pune. Pan: Aaajb 0024 D Appellant Respondent Shri Bhagwant Multistate Vs Pr.Cit-4, Pune. Credit Co-Op. Society Ltd., 739/7/17, Patil Plot, Shivaji Nagar Barshi, Solapur. Pan: Aamas 3645 L Appellant Respondent

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed

BAJAJ AUTO EMPLOYEES CO OP CREDIT SOCIETY LTD,PUNE vs. INCOME TAX OFFICER, CIRCLE-8, PUNE, PUNE

In the result, appeals of the assessees are allowed

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.The Mahatma Sahakari Griha Vs Pr.Cit-2, Pune. Rachana Sanstha Maryadit, S.No.62 & 65, Sahakar Bhavan, Kothrud, Pune. Pan: Aabtt 5342 F Appellant Respondent Bajaj Auto Employees Co-Op Vs Ito, Ward-8, Credit Society Ltd., Bombay Pune. Pune Road, Bajaj Auto Ltd., Plot No.393/394, Sector 21, Akurdi, Pune. Pan: Aaajb 0024 D Appellant Respondent Shri Bhagwant Multistate Vs Pr.Cit-4, Pune. Credit Co-Op. Society Ltd., 739/7/17, Patil Plot, Shivaji Nagar Barshi, Solapur. Pan: Aamas 3645 L Appellant Respondent

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed

PIMPIRI CHINCHWAD MAHANAGAR PALIKAS SEVAKANCHI PATSANSTHA MARYADIT,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX,, PUNE

In the result, appeal of the assessee is allowed

Bench: Shri R.S. Syal, Hon.Vice- & Shri Partha Sarathi Chaudhury, Hon.Pimpri Chinchwad Mahanagar Vs Pr.Cit, Pune. Palika‟S Sevakanchi Patsanstha Maryadit, Shop No.101, Shubham Galleria, Pimpri, Pune. Pan: Aaatp 5109 P Appellant Respondent Assessee By : Shri Rohit C. Kasat, Ca Revenue By : Shri Ajay Kumar Kesari, Dr Date Of Hearing : 17/08/2023 Date Of Pronouncement : 21/08/2023 O R D E R Per Partha Sarathi Chaudhury, Jm: This Appeal Preferred By The Assessee Emanate From The Order Of Principal Commissioner Of Income Tax, Pune (For Short, „Pcit‟), Dated 23/03/2022 For A.Y. 2017-18 As Per The Grounds Of Appeal On Record.

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 2 Pimpri Chinchwad Mahanagar Palika‟s Sevakanchi Patsanstha Maryadit. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However

KIRLOSKAR OIL ENGINE EMPLOYEES CO- OP CREDIT SOCIETY LTD,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE-2, PUNE

In the result, the appeal of assessee is allowed

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed

SHRI PARSHWANATH NAGARI SAHAKARI PATHSANSTH,SATARA vs. DCIT, CENTRAL CIRCLE 2(4), PUNE, PUNE

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

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

80P(2)(a) (i) of the Act can bring in illicit money into business without 8 fear of consequences. Further, profits and gains of business is a matter covered by Chapter IV of the Act and Section 68 of the Act is one falling under Chapter VI

BALWANTPURAM SAMRAJYA L6 HIJK CO-OPERATIVE HOUSING SOCIETY LIMITED,KOTHRUD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE-2, PUNE

In the result, the appeal of assessee is allowed

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed

BALWANTPURAM SAMRAHYA L-7 (LMNOP) CO-OPERATIVE HOUSING SOCIETY,KOTHRUD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE-2, PUNE

In the result, the appeal of assessee is allowed

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed

THE INCOME TAX OFFICER, WARD-10(1), PUNE vs. VASANTRAO NAIK NAGARI SAHAKARI PATSANSTHA , PUNE

Appeal is dismissed in above terms

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

vi) Sant Motiram Maharaj Patsanstha Ltd. vs. ITO, 120 taxmann.com 10. 5. It is further submitted that the Assessing Officer had allowed the claim of exemption after due application of mind on the issue in appeal and, therefore, the Explanation 2 to section 263 cannot be invoked. However, the ld. PCIT on due consideration of explanation filed