THE WANKA VIVIDH KARYAKARI SEVA SAHKARI MANDALI LTD,TAPI vs. THE INCOME TAX OFFICER, WARD2 BARDOLI, BARDOLI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Pawan Singhआ.अ.सं./Ita No.470/Srt/2023 (Ay 2017-18) (Hearing In Physical Court) The Wanka Vividh Karyakari Seva Income Tax Officer, Sahkari Mandali Ltd. Ward-2, Bardoli, Income Vs At & Po Wanka, Taluka-Nizar, Tax Office, 2Nd Floor, Bsnl Tapi-394370 Building, Opp. Jalaram Akshaymodi40@Gmail.Com Temple, Station Road, Pan No: Aahft 1009 K Bardoli-394601 अपीलाथ"/Appellant ""थ" /Respondent

2((d) the assessee failed to file return of income and as per provision of Section 80A(P). The assessee is not eligible for claiming such deduction. The Ld. CIT(A) also held that assessee had optioned to file partition before jurisdictional Commissioner for condonation of delay in filing returned of income. 6. I find that in the present appeal

SHRAMDEEP URBAN CO OP. CREDIT SO. LTD.,SURAT vs. ACIT CIRCLE-3(3), SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.892/Srt/2024 Assessment Year: (2017-18) (Physical Hearing) Shramdeep Urban Co-Operative Credit Vs. The Acit, Society Limited, Circle -3(3), 11-12, Harekrushna Shopping Complex, Surat Varachha Road, Varachha, Surat - 395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaas3229C (Appellant) (Respondent) Appellant By Shri Rushi Parekh, Ar Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 30/12/2024 Date Of Pronouncement 03/02/2025

d) after deduction related expenses and overheads. The assessee also earned Rs.2,95,564/- by providing locker facility and claimed deduction of Rs.32,446/- u/s 80P(2)(a) of the Act, which was not related to the activity of providing credit facilities to its members. The AO reproduced the comparative analysis regarding Co-operative society and Co-operative bank, which

THE SURAT DISTRICT CO. OP. BANK LTD.,,SURAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2),, SURAT

In the result, appeal of assessee for A

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) The Surat District Co- Deputy Commissioner Of Operative Bank Ltd., Income Tax, Vs Kanpith, Lalgate, Circle-2(2), Aayakar Bhavan, Surat-395003 Majura Gate, Pan : Aaaat 2985 Q Surat. Appellant / Revenue Respondent / Assessee

80P ;' 16. We find that the assessee made a provision under section 36(1)(viia) of Rs. 7.16 Crore, the assessing Officer disallowed the claim to the extent of Rs.3.66 crores out of total claim of assessee under section 36(1)(viia) by taking view that the aforesaid amount under four heads are not provision for bad and doubtful debts

THE ASSTT. CIT., CIRCLE - 2(2),, SURAT vs. THE SURAT DISTRICT CO. OPERATIVE BANK LTD.,, SURAT

In the result, appeal of assessee for A

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) The Surat District Co- Deputy Commissioner Of Operative Bank Ltd., Income Tax, Vs Kanpith, Lalgate, Circle-2(2), Aayakar Bhavan, Surat-395003 Majura Gate, Pan : Aaaat 2985 Q Surat. Appellant / Revenue Respondent / Assessee

80P ;' 16. We find that the assessee made a provision under section 36(1)(viia) of Rs. 7.16 Crore, the assessing Officer disallowed the claim to the extent of Rs.3.66 crores out of total claim of assessee under section 36(1)(viia) by taking view that the aforesaid amount under four heads are not provision for bad and doubtful debts

THE ASSTT. CIT., CIRCLE - 2(2),, SURAT vs. THE SURAT DISTRICT CO. OPERATIVE BANK LTD.,, SURAT

In the result, appeal of assessee for A

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) The Surat District Co- Deputy Commissioner Of Operative Bank Ltd., Income Tax, Vs Kanpith, Lalgate, Circle-2(2), Aayakar Bhavan, Surat-395003 Majura Gate, Pan : Aaaat 2985 Q Surat. Appellant / Revenue Respondent / Assessee

80P ;' 16. We find that the assessee made a provision under section 36(1)(viia) of Rs. 7.16 Crore, the assessing Officer disallowed the claim to the extent of Rs.3.66 crores out of total claim of assessee under section 36(1)(viia) by taking view that the aforesaid amount under four heads are not provision for bad and doubtful debts

ASSISTANT COMMISSIONER OF INCOME TAX, CIR.2(1)(1), SURAT vs. THE SURAT DISTRICT CO-OP. BANK LTD., SURAT

In the result, ground No.1& 3 raised by the Revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Assistant Commissioner The Surat District Co- Of Income Tax, Operative Bank Ltd. Vs Circle-2(1)(1), 1, Kanpith, Lalgate, Surat. Surat-395003 Pan : Aaaat 2985 Q Appellant / Revenue Respondent / Assessee

80P ;' 16. We find that the assessee made a provision under section 36(1)(viia) of Rs. 7.16 Crore, the assessing Officer disallowed the claim to the extent of Rs.3.66 crores out of total claim of assessee under section 36(1)(viia) by taking view that the aforesaid amount under four heads are not provision for bad and doubtful debts

THE SURAT DISTRICT CO-OP. BANK LTD,SURAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2), SURAT, SURAT

In the result, ground No.6 raised by the assessee, is allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.590/Srt/2019 Assessment Year: (2011-12) (Physical Hearing) The Surat District Co.Op. Bank Ltd., Vs. The Acit, Circle-2(2), Shri Pramodbhai Desai Sahakar Bhavan, Surat. J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent) आयकर अपील सं./Ita No.4/Srt/2020 Assessment Year: (2011-12) The Dcit, Circle-2(2), Vs. The Surat District Co.Op. Bank Ltd., Surat. Shri Pramodbhai Desai Sahakar Bhavan, J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent)

80P ;' 16. We find that the assessee made a provision under section 36(1)(viia) of Rs. 7.16 Crore, the assessing Officer disallowed the claim to the extent of Rs.3.66 crores out of total claim of assessee under section 36(1)(viia) by taking view that the aforesaid amount under four heads are not provision for bad and doubtful debts

DCIT, CIRCLE-2(2), SURAT vs. THE SURAT DISTRICT CO-OP. BANK LIMITED, SURAT

In the result, ground No.6 raised by the assessee, is allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.590/Srt/2019 Assessment Year: (2011-12) (Physical Hearing) The Surat District Co.Op. Bank Ltd., Vs. The Acit, Circle-2(2), Shri Pramodbhai Desai Sahakar Bhavan, Surat. J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent) आयकर अपील सं./Ita No.4/Srt/2020 Assessment Year: (2011-12) The Dcit, Circle-2(2), Vs. The Surat District Co.Op. Bank Ltd., Surat. Shri Pramodbhai Desai Sahakar Bhavan, J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent)

80P ;' 16. We find that the assessee made a provision under section 36(1)(viia) of Rs. 7.16 Crore, the assessing Officer disallowed the claim to the extent of Rs.3.66 crores out of total claim of assessee under section 36(1)(viia) by taking view that the aforesaid amount under four heads are not provision for bad and doubtful debts

V. M. MANIYAR EXPORTS,SURAT vs. DCIT, CIRCLE 2(2), SURAT

In the result, assessee’s appeal is allowed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1368/Srt/2024 Assessment Year : 2015-16 (Hybrid Hearing) V.M.Maniyar Exports Assistant Commissioner Of बनाम/ Plot No.103-104, Surat Income-Tax, Circle-2(2), Surat Vs. Special Economic Zone, Gidc, Sachin,Surat-394230 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaifv 6884 F (अपीलाथ"/Appellant) (""थ" /Respondent)

D E R PER BIJAYANANDA PRUSETH, AM: This appeal by the assessee emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, ‘the Act’), dated 10.12.2024 by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [in short, ‘CIT(A)’] for the Assessment Year (AY) 2015-16, confirming the penalty levied

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

d) debentures and bonds, (e) subsidiaries/joint ventures, and (f) other (CP Mutual Fund Units, etc.). (ii) Banks should decide the category of the investment at the time of acquisition and the decision should be recorded on the investment proposals. 2.3 Shifting among categories : (i) Banks may shift investments to/from Held to maturity category with the approval of the Board

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

d) debentures and bonds, (e) subsidiaries/joint ventures, and (f) other (CP Mutual Fund Units, etc.). (ii) Banks should decide the category of the investment at the time of acquisition and the decision should be recorded on the investment proposals. 2.3 Shifting among categories : (i) Banks may shift investments to/from Held to maturity category with the approval of the Board

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

d) debentures and bonds, (e) subsidiaries/joint ventures, and (f) other (CP Mutual Fund Units, etc.). (ii) Banks should decide the category of the investment at the time of acquisition and the decision should be recorded on the investment proposals. 2.3 Shifting among categories : (i) Banks may shift investments to/from Held to maturity category with the approval of the Board

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

d) debentures and bonds, (e) subsidiaries/joint ventures, and (f) other (CP Mutual Fund Units, etc.). (ii) Banks should decide the category of the investment at the time of acquisition and the decision should be recorded on the investment proposals. 2.3 Shifting among categories : (i) Banks may shift investments to/from Held to maturity category with the approval of the Board

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

d) debentures and bonds, (e) subsidiaries/joint ventures, and (f) other (CP Mutual Fund Units, etc.). (ii) Banks should decide the category of the investment at the time of acquisition and the decision should be recorded on the investment proposals. 2.3 Shifting among categories : (i) Banks may shift investments to/from Held to maturity category with the approval of the Board

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

d) debentures and bonds, (e) subsidiaries/joint ventures, and (f) other (CP Mutual Fund Units, etc.). (ii) Banks should decide the category of the investment at the time of acquisition and the decision should be recorded on the investment proposals. 2.3 Shifting among categories : (i) Banks may shift investments to/from Held to maturity category with the approval of the Board

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

d) debentures and bonds, (e) subsidiaries/joint ventures, and (f) other (CP Mutual Fund Units, etc.). (ii) Banks should decide the category of the investment at the time of acquisition and the decision should be recorded on the investment proposals. 2.3 Shifting among categories : (i) Banks may shift investments to/from Held to maturity category with the approval of the Board

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

d) debentures and bonds, (e) subsidiaries/joint ventures, and (f) other (CP Mutual Fund Units, etc.). (ii) Banks should decide the category of the investment at the time of acquisition and the decision should be recorded on the investment proposals. 2.3 Shifting among categories : (i) Banks may shift investments to/from Held to maturity category with the approval of the Board