BATAVA DEVLI SEVA SAHAKARI MANDALI LTD.,BATAVA DEVLI, TAL. KUNLAVA, DIST. AMRELI. vs. THE ADIT, (CPC), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

80P could be disallowed in section 143(1)(a)(ii) of the Act, especially in the fact that the scope of sub- clause (ii) has been specifically defined in section 143(1). As observed earlier, in our view, the scope of sub- clause (ii) of section 143(1)(a) does not cover delay in filing of return of income beyond

SHREE SANALIYA SEVA SAHKARI MANDLI LTD.,LITAL MOTALILIYA SANALIYA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

4) of the Act. Therefore, the rejection of return cannot be the criteria. The Ld. AR further submitted that the debatable issue in respect of pima facie adjustment cannot be taken into account by disallowing the claim under Section 80P

AMBARADI SEVA SAHKARI MANDALI LTD.,AMBARADI , DIST. AMRELI vs. THE DCIT(CPC), BANGALURU, BENGALURU

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

4) of the Act. Therefore, the rejection of return cannot be the criteria. The Ld. AR further submitted that the debatable issue in respect of pima facie adjustment cannot be taken into account by disallowing the claim under Section 80P

DHARESHWAR SEVA SAHAKARI MANDALI LTD. ,VILLAGE: - DHARESHWAR, TALUKA: - RAJULA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

4) of the Act. Therefore, the rejection of return cannot be the criteria. The Ld. AR further submitted that the debatable issue in respect of pima facie adjustment cannot be taken into account by disallowing the claim under Section 80P

AMRUTPUR SEVA SAHKARI MANDALI LTD.,VILLAGE: - AMRUTPUR TALUKA DHARI, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

4) of the Act. Therefore, the rejection of return cannot be the criteria. The Ld. AR further submitted that the debatable issue in respect of pima facie adjustment cannot be taken into account by disallowing the claim under Section 80P

ALIADAR SEVA SAHAKARI MANDLI LTD.,,GIR SOMNATH vs. INCOME TAX OFFICER, WARD-4, , VERAVAL

In the result, appeal of the assessee is dismissed

disallowed deduction under section 80P on interest income of Rs. 39,11,617/-. Appeal to the CIT(A)-3 did not bring any relief to the appellant. 3. The Ld. CIT (A) has erred in charging interest u/s. 234 in absence of the specific instruction under the Assessment order, my kindly be deleted 4

ALIDAR SEVA SAHAKARI MANDLI LTD.,,GIR SOMNATH vs. INCOME TAX OFFICER, WARD-4,, VERAVAL

In the result, appeal of the assessee is dismissed

disallowed deduction under section 80P on interest income of Rs. 39,11,617/-. Appeal to the CIT(A)-3 did not bring any relief to the appellant. 3. The Ld. CIT (A) has erred in charging interest u/s. 234 in absence of the specific instruction under the Assessment order, my kindly be deleted 4

ALIDAR SEVA SAHAKARI MANDLI LTD.,,GIR SOMNATH vs. INCOME TAX OFFICER, WARD-4,, VERAVAL

In the result, appeal of the assessee is dismissed

disallowed deduction under section 80P on interest income of Rs. 39,11,617/-. Appeal to the CIT(A)-3 did not bring any relief to the appellant. 3. The Ld. CIT (A) has erred in charging interest u/s. 234 in absence of the specific instruction under the Assessment order, my kindly be deleted 4

SURENDRANAGAR DISTRICT CO OP PRODUCERS UNION LIMITED,SURENDRANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, SURENDRANAGAR CIRCLE

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

4,81,15,151/-( Rs.3,63,33,085 + Rs.1,17,82,066), how to off that Rs. 1,17,82,066/- is eligible for deduction under section 80P (2) (d) of the Act.The learned Counsel further clarified the Bench that Ld.CIT(A) has wrongly confirmed the disallowance

RAJKOT DISTRICT CO-OP. BANKS EMPLOYEES M P CREDIT CO-OP. LTD.,RAJKOT vs. THE DCIT/ACIT CIR 1(1), RAJKOT

In the result, appeal of the assessee is allowed

disallowing\nclaim of deduction of Rs. 4,83,300/- made by the Appellant u/s. 80(2)(d) of the Act by\nway of order u/s. 154 r.w.s. 250 of the Income Tax Act, 1961.\n3) The Ld. Commissioner (Appeals), NFAC, Delhi failed to appreciate the true import\nof decision of Gujarat High Court in the case of KatlayKariyana Merchant\nSahkariSarafiMandali

SHRI TRAMBAKPUR SAHAKARI MANDALI LIMITED,AT TRAMBAKPUR TALUKA DHARI DIST. AMRELI vs. THE DCIT/ACIT (CPC),, BANGALORE

In the result, appeal of the assessee is allowed

disallowing deduction of Rs. I.T.A No. 23/Rjt/2022 A.Y. 2019-20 Page No 3 Shri Trambakpur Sahkari Mandali Ltd. vs. DCIT/ACIT(CPC) 4,11,630/- claimed by the Appellant under various sub-sections of Sec. 80P

CHAKARGADH SEVA SAHAKARI MANDALI LTD.,CHAKARGADH SEVA, DIST. AMRELI vs. THE DCIT(CPC),, BENGALURU

In the result, appeal of the assessee is allowed

Bench: Shri Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

4), in which claim for deduction under section I.T.A No. 187/Rjt/2022 A.Y. 2019-20 Page No 11 Chakargadh Seva Sahakari Mandali Ltd. vs. DCIT (CPC) 80P was made, therefore, deduction under section 80P could not be denied to assessee only on basis that assessee did not file its return of income within due date prescribed under section

KUTCH DISTRICT CO-OPERATIVE MILK PRODUCERS UNION LTD.,ANJAR - KUTCH vs. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NEW DELHI

disallowed and added to the income of the\nassessee for the year under consideration. Penalty u/s 270A of the Act is initiated\nfor under reporting of income.\"\nHowever, we note that in the computation of total income, the Assessing\nOfficer by mistake took the figure at Rs.5,87,74,816/-, instead of correct figure of\nRs.5

DAHIDA SEVA SAHAKARI MANDALI LIMITED ,VILLAGE: - DAHIDA, DIST.:- AMRELI vs. THE ADIT (CPC), BENGALURU, BENGALURU

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

disallowance of deduction claimed under any of the provisions of Chapter VI-A under the heading "C.—Deductions in respect of certain incomes" (which includes deduction under section 80P of the Act), can be made if the return is furnished beyond the due date specified under sub-section (1) of section 139. This amendment has been introduced w.e.f

SHREE ANTALIYA KHETI VIKAS KARYAKARI SEVA SAHAKARI MANDALI LIMITED,LILIYA MOTA, DIST. AMRELI vs. THE ADIT (CPC), BANGALURU, BENGALURU

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

disallowance of deduction claimed under any of the provisions of Chapter VI-A under the heading "C.—Deductions in respect of certain incomes" (which includes deduction under section 80P of the Act), can be made if the return is furnished beyond the due date specified under sub-section (1) of section 139. This amendment has been introduced w.e.f

ALIUDEPUR SEVA SAHAKARI MANDALI LIMITED,ALIUDEPUR VILLAGE, TALUKA LATHI, DIST.: - AMRELI-365430 vs. THE ADIT (CPC), BENGALURU, BENGALURU

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

disallowance of deduction claimed under any of the provisions of Chapter VI-A under the heading "C.—Deductions in respect of certain incomes" (which includes deduction under section 80P of the Act), can be made if the return is furnished beyond the due date specified under sub-section (1) of section 139. This amendment has been introduced w.e.f

SHREE KESHAV CO OP CREDIT SOCIETY LTD,JUNAGADH vs. THE DCIT/ACIT, CIR - 1(1), RAJKOT, RAJKOT

In the result, both appeals filed by the assessee, are allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

disallowing the same u/s 80P(2)(a)(i) of the Act. 3. The learned Commissioner (Appeals), National Faceless Appeal Centre (NFAC), Delhi failed to appreciate that alternatively, the whole of interest derived by cooperative society from its investments with any other co-operative society was also deductible u/s 80P(2)(d) of the Act by disregarding decisions of jurisdictional High

SHREE KESHAV CO OP CREDIT SOCIETY LTD,JUNAGADH vs. THE DCIT/ACIT, CIR 1(1), RAJKOT, RAJKOT

In the result, both appeals filed by the assessee, are allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

disallowing the same u/s 80P(2)(a)(i) of the Act. 3. The learned Commissioner (Appeals), National Faceless Appeal Centre (NFAC), Delhi failed to appreciate that alternatively, the whole of interest derived by cooperative society from its investments with any other co-operative society was also deductible u/s 80P(2)(d) of the Act by disregarding decisions of jurisdictional High

SHREE LUNIDHAR SEVA SAHKARI MANDALI LTD.,LUNIDHAR, TALUKA KUNKAVAV, DIST. AMRELI. vs. ASSESSING OFFICER (CPC), , BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

disallowance of deduction claimed under any of the provisions of Chapter VI-A under the heading "C.— Deductions in respect of certain incomes" (which includes deduction under section 80P of the Act), can be made if the return is furnished beyond the due date specified under sub-section (1) of section 139. This amendment has been introduced w.e.f