THE GOVERNMENT E CO-OPERATIVE SOCIETY LTD.,,BHARUCH vs. PRINCIPAL COMMISSIONER OF INCOME TAX , VADODARA-1, VADODARA

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.126/Srt/2023 (Ay 2017-18) (Hearing In Virtual Court) The Government E Co- Principal Commissioner Of Operative Society Ltd./, Income Tax, Vadodara-1, Vs First Floor, Government Room No.214, 2Nd Floor, Sevasadan, Bhag-2, B/H Aaykar Bhawan, Race Course Pwd Office, Bharuch- Circle, Vadodara-390007 392001 Pan No. Aaalt 0832 D अपीलाथ"/Appellant ""थ" /Respondent

B. Koli, CIT-DR अपील पंजीकरण/Appeal instituted on 20.02.2023 सुनवाई की तारीख/Date of hearing 23.05.2023 उद्घोषणा की तारीख/Date of 23.05.2023 pronouncement Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of ld. Principal Commissioner of Income-tax-Valsad [for short

GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,,NA vs. ARIVS.INCOME TAX OFFICER WARD-2, NAVSARI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

B. The Learned Commissioner (Appeals) has confirmed the ratio calculated by the Learned assessing Officer but it is implemented wrongly by the Learned assessing Officer regarding the relief of section 80P(2)(a)(iv). We have provided the details fully. In fact, it is a mathematical mistake to be rectified will result into the deletion of Rs.33,66,477/- from

ASSISTANT COMMISSIONER OF INCOME TAX,, NA vs. ARIVS.GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,, NAVSARI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

B. The Learned Commissioner (Appeals) has confirmed the ratio calculated by the Learned assessing Officer but it is implemented wrongly by the Learned assessing Officer regarding the relief of section 80P(2)(a)(iv). We have provided the details fully. In fact, it is a mathematical mistake to be rectified will result into the deletion of Rs.33,66,477/- from

GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,,NA vs. ARIVS.INCOME TAX OFFICER WARD-2, NAVSARI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

B. The Learned Commissioner (Appeals) has confirmed the ratio calculated by the Learned assessing Officer but it is implemented wrongly by the Learned assessing Officer regarding the relief of section 80P(2)(a)(iv). We have provided the details fully. In fact, it is a mathematical mistake to be rectified will result into the deletion of Rs.33,66,477/- from

ASSISTANT COMMISSIONER OF INCOME TAX,, NA vs. ARIVS.GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,, NAVSARI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

B. The Learned Commissioner (Appeals) has confirmed the ratio calculated by the Learned assessing Officer but it is implemented wrongly by the Learned assessing Officer regarding the relief of section 80P(2)(a)(iv). We have provided the details fully. In fact, it is a mathematical mistake to be rectified will result into the deletion of Rs.33,66,477/- from

M/S SACHIN UDYOG NAGAR SAHKARI MANDLI LTD.,,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(2), SURAT

In the result, the appeal of the Revenue is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.438 & 439/Srt/2022 Assessment Years: (2017-18 & 2018-19) (Virtual Court Hearing) Sachin Udyog Nagar Sahkari Mandli Vs. The Acit, Circle -1(2), Ltd., Surat. 2Nd Floor, Vivekanand Chambers, Beside Rajehree Hall, Sangrampura, Surat – 395006. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacts7414C (Appellant) (Respondent) Assessee By Shri Kamlesh Bhatt, Ar Respondent By Shri Ashok B. Koli, Cit(Dr) & Vinod Kumar, Sr. Dr 07/02/2023 Date Of Hearing Date Of Pronouncement 07/02/2023 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Two Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2017-18 & 2018-19, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Surat [In Short “The Ld. Cit(A)”], Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

section doesn’t bar the deduction of interest received by cooperative society from a cooperative bank. The deduction was being allowed for several preceding assessment years in the case of the appellant society. The AR has referred to decisions of the 438 & 439/SRT/2022/AY.2017-18 & 2018-19 Sachin Udyog Nagar Sahkari Mandli Ltd. jurisdictional High Court and jurisdiction ITAT Benches wherein

ASSISTANT COMMISSIONER OF INCOME -TAX, CIRCLE-1(1)(1),SURAT, MAJURA GATE,SURAT vs. SHREE ARADHNA URBAN CO OP CREDIT SOCIETY LTD, VARACHHA ROAD

In the result, this appeal of revenue is dismissed

Bench: Shri Pawan Singh(Hybrid Hearing) A.C.I.T., Shree Aradhna Urban Co Op Credit Circle-1(1)(1), Society Ltd., Vs. Surat. 128-129, Super Diamond Market, Varachha Road, Surat-395006. Pan No. Aaopc 8463 B Appellant/Revenue Respondent/Assessee

B Appellant/Revenue Respondent/Assessee Assessee represented by Shri Akshay Mitish Kumar Modi, C.A. Department represented by Shri Vinod Kumar, Sr. DR Appeal instituted on 24/07/2023 Date of hearing 28/11/2023 Date of pronouncement 28/11/2023 Order under Section 254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the Revenue is directed against the order of National Faceless

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

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

disallowance of deduction u/s 80P(2)(d)(i) of Rs.2,95,564/- being identical income of locker rent received by providing locker facility to member only and holding the same to be not income from business of banking as the assessee society is not holding banking license to operate locker. 2. Alternative, CIT(A) could have granted the deduction

AMALSAD VIBHAG VIVISH KARYAKARI SAHKARI KHEDUT MANDLI LTD.,NA vs. ARIVS.PCIT, VALSAD

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.491/Srt/2024 Ays: 2018-19 (Physical Court Hearing) Amalsad Vibhag Vividh Principal Commissioner Of Karyakari Sahkari Khedut Income Tax, Valsad, 301/3Rd Vs. Mandli Ltd., At & Po. Floor, Palak Arcade, Shanti Amalsad, Tal. Gandevi, Nagar, Tithal Road, Valsad-396 Dist. Navsari-396 310 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaaa 1043 N (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri P.M Jagasheth, Ca राज" की ओर से /Revenue By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 17.12.2024 उद्घोषणा की तारीख/Date Of Pronouncement 03.02.2025

disallowing the said deduction u/s 57 of the Act. The Ld. PCIT also addressed the issue with regard to assessee's argument about the reliance on ITAT rulings instead of jurisdictional High Court or Supreme Court decisions. The Ld. PCIT clarified that while the judgments referred to were from the ITAT, the said judgments had cited the relevant decisions from

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

B Koli, CIT-DR with Shri Vinod Kumar, Sr.DR Assessee represented by Shri Manish J Shah, AR Date of hearing 05/01/2023 Date of pronouncement 09/01/2023 Order under Section 254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. These three appeals by the Revenue are directed against the separate orders of National Faceless Appeal Centre, Delhi (NFAC)/learned

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

B Koli, CIT-DR with Shri Vinod Kumar, Sr.DR Assessee represented by Shri Manish J Shah, AR Date of hearing 05/01/2023 Date of pronouncement 09/01/2023 Order under Section 254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. These three appeals by the Revenue are directed against the separate orders of National Faceless Appeal Centre, Delhi (NFAC)/learned

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

B Koli, CIT-DR with Shri Vinod Kumar, Sr.DR Assessee represented by Shri Manish J Shah, AR Date of hearing 05/01/2023 Date of pronouncement 09/01/2023 Order under Section 254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. These three appeals by the Revenue are directed against the separate orders of National Faceless Appeal Centre, Delhi (NFAC)/learned