NO H 1043 BHUJABALAPATNAM PRIMARY AGRICULTURE COOPERATIVE CREDIT SOCIETY LTD,KRISHNA DIST vs. INCOME TAX OFFICER, WARD-1, GUDIWADA

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

Bench: The Tribunal. The Petitioner/Appellant Society Has Filed An Affidavit Explaining The Reasons For The Delay In Filing The Appeal Before The Tribunal, Wherein It Was Submitted That The Order Passed By The Ld. Cit(A) Was Sent To The Email Of Its Then Ar, Ca B.V. Rao, Instead Of Its Email "Krishnapacs085@Gmail.Com," As Had Been Requested By It. The Appellant Society Came To Know Of The Order Only When Itd Officials Called Upon It To Pay The Tax Arrears. It Further Submitted That, Due To The Above Circumstances Beyond Its Control & Prayed That The Delay Of 69 Days In Filing The Appeal Before The Tribunal May Please Be Condoned In The Interest Of Justice & That The Appeal Be Decided On Merits.

2. At the outset, there is a delay of 69 days in filing the appeal before the Tribunal. The petitioner/appellant society has filed an affidavit explaining the reasons for the delay in filing the appeal before the Tribunal, wherein it was submitted that the order passed by the Ld. CIT(A) was sent to the email of its then

THE CHINAOGIRALA PACS LTD,CHINAOGIRALA VILLAGE vs. INCOME TAX OFFICER, WARD 1, GUDIVADA, GUDIVADA

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.296/Viz/2023 (निर्धारण वर्ा / Assessment Year : 2020-21) The Chinaogirala Pacs Ltd, Vs. Income Tax Officer, Chinaogirala Village, Ward-1, Vuyyuru Mandal, Gudivada, Krishna District, Andhra Pradesh-521301. Andha Pradesh-521245. Pan: Aacat 8188 M (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थी की ओर से/ Appellant By : None प्रत्यधर्थी की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

condoning the delay in filing the appeal though the delay was due to the circumstances beyond the control and with no comments on the grounds of appeal. The Andhra Pradesh high court held in the case of Pinjari Khasim v Chanda Saheb, 2023 SCC OnLine AP 698, decided on 28-03-2023 that “…. ordinarily the litigation should not be terminated

THE FARMERS SERVICE CO-OPERATIVE LIMITED,SRIKAKULAM vs. INCOME-TAX OFFICER, WARD-1, SRIKAKULAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.166/Viz/2024 (िनधा"रण वष" / Assessment Year: 2018-19) The Farmers Service Co-Operative Vs. Income Tax Officer, Limited, Ward-1, Srikakulam. Srikakulam. Pan: Aabtt4377L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri I. Kama Sastry, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 24/06/2024 घोषणा क" तारीख/Date Of : 14/08/2024 Pronouncement O R D E R

condonation of delay along with the affidavit and the relevant paras of the affidavit is extracted herein below for reference: “1……. 2…….. 3. The in the computation sheet accompanying the order the business income of the assessee is taken at Rs. 48,34,258/- as against the income from business before deduction under 80P returned by the assessee

THE FARMERS SERVICE CO-OP LTD.,,RANASTHALAM vs. INCOME-TAX OFFICER WARD-1, SRIKAKULAM, SRIKAKULAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.310/Viz/2023 ("नधा"रण वष" / Assessment Year :2020-21) The Farmers Service Co-Op. Ltd., Vs. Income Tax Officer, Ranasthalam, Ward-1, Srikakulam-532407. Srikakulam. Pan: Aabtt 4377 L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri I Kama Sastry, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

condonation of delay along with the affidavit and the relevant paras of the affidavit is extracted herein below for reference: “1……. 2…… 3…… 4…… 5…… 6. The Ld. CIT(A), NFAC vide his order dated 14/7/2003 disallowed the claim for deduction under section 80P

SRI LAKSHMI VENKATESWARA MUTUALLY AIDED COOPERATIVE SOCIETY LIMITED,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1(1), VISAKHAPATNAM

Bench: Shri K. Narasimha Chary, Hon'Ble & Shri S Balakrishnan, Hon'Bleआयकर अपीलसं./I.T.A.No. 140/Viz/2024 (निर्धारण वर्ष/ Assessment Year: 2018-19) Sri Lakshmi Venkateswara Mutually Aided Cooperative Society Limited D.No. 49-12-33 Lalitha Temple Street Lalitha Nagar, Akkayyapalem Visakhapatnam – 530016 Andhra Pradesh [Pan: Aadas2078L] (अपीलार्थी/ Appellant) V. Income Tax Officer – Ward – 1(1) Income Tax Office Pratyakshakar Bhavan Mvp Colony, Visakhapatnam – 530017 Andhra Pradesh (प्रत्यर्थी/ Respondent) करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement : Smt A. Aruna, Advocate : Dr. Aparna Villuri, Sr. Ar : 06.02.2025 : 20.02.2025 आदेश /Order Per Shri S Balakrishnan: 1. This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter In Short "Ld.Cit(A)"] Vide Din & Order No.

condone the delay of 346 days in filing the appeal before the Tribunal and proceed to adjudicate the appeal on merits in the following paragraphs. 4. Brief facts of the case are that, assessee is a cooperative society registered under AP State Mutually Aided Co-operative Societies Act 1995 and has been carrying the business of credit among the members

OMMI SANDEEP,VIZIANAGARAM vs. INCOME TAX OFFICER, WARD-1, VIZIANAGARAM

Bench: Shri Sandeep Singh Karhail, Hon'Ble & Shri Omkareshwar Chidara, Hon'Bleआयकर अपील सं./I.T.A. No. 247/Viz/2025 (निर्धारण वर्ष/ Assessment Year:2017-18) The Chinnampeta Primary Agricultural Cooperative Credit Society Limited Chinnampeta Village Chinnampeta Post, Chatrai Mandal Krishna – 521214, Andhra Pradesh [Pan: Aacat7997E] (अपीलार्थी/ Appellant) करदाता का प्रतिनिधित्व / Assessee Represented By राजस्व का प्रतिनिधित्व / Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement V. Income Tax Officer, Ward – 3(5) C.R. Building, 1St Floor Annex M.G. Road, Vijayawada Andhra Pradesh (प्रत्यर्थी / Respondent) Shri C. Subrahmanyam, Ca Dr. Aparna Villuri, Sr.Ar 16.12.2025 24.02.2026 आदेश /Order Per Omkareshwar Chidara: 1. The Present Appeal Is Filed By The Assessee Against The Impugned Order Dated 31.10.2025, Passed Under Section 250 Of The Income Tax Act, 1961 (In Short 'Act') By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter In Short “Ld.Cit(A)”], For The A.Y. 2017-18.

condone the delay of 24 days Page No. 2 in filing the appeal before the Tribunal and proceed to adjudicate the appeal on merits in the following paragraphs. 4. The only issue to be adjudicated in the above cited appeal is whether the Appellant Cooperative Society is entitled for deduction under section 80P

PANDALAPAKA PRIMARY AGRICULTURAL CO-OP CREDIT SOCIETY LTD,EAST GODAVARI vs. INCOME-TAX OFFICER-WARD-1, KAKINADA

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.437 & 438/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19 & 2020-21) Pandalapaka Primary Agricultural V. Income Tax Officer – Ward – 1 Income Tax Office Co-Op Credit Society Ltd., 3Rd Floor, Deepthi Towers 5-28/1, Pandalapaka Main Road, Kakinada – 533001 Biccavole Mandal – 533345 Andhra Pradesh [Pan: Aabap2382G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

condonation of delay and read out the contents of the petition which is as under: Page No. 11 I.T.A.Nos.437 & 438/VIZ/2024 Pandalapaka Primary Agricultural Co-op Credit Society Ltd., “1. That the society has filed a return of income for the Assessment Year2020-21 on 28.12.2020 returning a taxable income of NIL after claiming deduction under section 80P 2

THE P A C S NOH 1002,PACS VELVADAM vs. INCOME TAX OFFICER, WARD 3(5), VIJAYAWADA

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

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.199/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) The P.A.C.S Noh 1002 V. Income Tax Officer – Ward – 3(5) Pacs Velvadam, Velvadam Post C.R. Building Mylavaram, Krishna District – 521230 Andhra Pradesh Andhra Pradesh [Pan: Aabap8170G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

2 I.T.A.No.199/VIZ/2024 The P.A.C.S NOH 1002 reasonable and sufficient cause in filing the appeal beyond the prescribed time limit with a delay of 28 days. Therefore, we hereby condone the delay of 28 days in filing the appeal before the Tribunal and proceed to adjudicate the appeal on merits in the following paragraphs. 4. Brief facts of the case

THE TENALI PT EMPLOYEES MUTUALLY AIDED CO OP THRIFT CREDIT SOCIETY LTD,TENALI vs. INCOME TAX OFFICER, WARD-1, TENALI

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 361/Viz/2025 (A.Y. 2019-20) The Tenali P & T Employees V. Income Tax Officer - Ward – 1 Mutually Aided Co-Op Thrift & Income Tax Office Credit Society Limited Opp. Sai Baba Temple, Bose Road D.No. 22-5-60, Sarojini Naidu Street Tenali – 522201, Andhra Pradesh Tanali – 522201 Andhra Pradesh [Pan:Aacat9757E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 143(1) of Income Tax Act, 1961 (in short ‘Act’) dated 01.05.2020. 2. At the outset, Ld. Authorised Representative [hereinafter in short “Ld.AR”], inviting our attention to the order of the Ld.CIT(A) submitted that the Ld.CIT(A) did not condone the delay of 526 days in filing the appeal stating that submissions are vague and dismissed the appeal

THE VAZRAPUKOTTURU PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,SRIKAKULAM vs. INCOME TAX OFFICER, WARD-1, SRIKAKULAM

In the result, appeal of the assessee is allowed

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.439/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2018-19) The Vazrapukotturu Primary V. Ito – Ward – 1 Income Tax Office, Aaykar Bhavan Agricultural Cooperative Credit Palakonda Road, Srikakulam – 532001 Society Limited Andhra Pradesh D.No. 12-3-71, Gandhi Nagar Kasibugga, Palasa, Srikakulam [Pan: Aadat1897J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

80P of the Act in the intimation passed under section 143(1) of the Act. 8. In this connection, at the outset, Ld. Authorised Representative [hereinafter “Ld.AR”] submitted that the assessee has filed the condonation of Page No. 4 I.T.A.No.439/VIZ/2024 The Vazrapukotturu Primary Agricultural Cooperative Credit Society Limited delay petition under section 119 (2

THE KONAYAPALEM PACS LTD.,CHANDARLAPADU MANDAL vs. ITO, WARD-1(3), VIJAYAWADA

In the result, appeal of the assessee is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.126/Viz/2022 ("नधा"रण वष" / Assessment Year : 2017-18) The Konayapalem Primary Vs. Income Tax Officer, Agricultural Cooperative Credit Ward-(3), Society Limited, Konayapalem Vijayawada. Village, Chandarlapadu Mandal, Krishna District, Andhra Pradesh – 521182. Pan: Aacat 6987 G (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri Asrss Siva Prasad, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

2. At the outset, it is noticed from the appeal record that there is a delay of 97 days in filing the appeal before the Tribunal. Explaining the reasons for belated filing of the appeal, the Ld. AR drawn my attention to the affidavit filed by the assessee along with petition seeking for condonation of delay and read

THE MUNDLAPADU PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,MUNDLAPADU VILLAGE vs. THE INCOME TAX OFFICER, WARD-1(3), VIJAYAWADA

In the result, appeal of the assessee is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.250/Viz/2024 (िनधा"रण वष" / Assessment Year : 2017-18) The Mundlapadu Primary Vs. The Income Tax Officer, Agricultural Cooperative Credit Ward-1(3), Society Limited, Mundlapadu Vijayawada. Village & Post, Penuganchiprolu Mandal, Krishna District, Andhra Pradesh – 521190. Pan: Aacat7977J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Smt. A. Aruna, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 15/07/2024 घोषणा क" तारीख/Date Of : 25/07/2024 Pronouncement O R D E R

condone the delay of 06 days in 3 filing the appeal before the Tribunal and proceed to adjudicate the appeal on merits in the following paragraphs. 4. Briefly stated the relevant facts of the case are that the assessee is a Primary Agricultural Cooperative Credit Society Limited. As per the information available with the Department, the assessee has deposited cash

ADIMULAM SATYANARAYANA PROPRIETOR,VIZIANAGARAM vs. INCOME TAX OFFICER, WARD-2, VIZIANAGARAM

In the result, appeal filed by the assessee is allowed in terms of my aforesaid observations

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member)

delay and allowed him to file his return of income under section 139(4) r.w.s 119(2)(b) of the Act for the subject year, but the assessee failed to furnish the same. 10. The AO based on the aforesaid facts holding a conviction that the assessee had failed to come forth with any explanation regarding the source

THE SALURU GIRIJAN CO OP MARKETING SOCIETY LIMITED,SALURU vs. INCOME TAX OFFICER, WARD-1, VIZIANAGARAM

In the result, the appeal of the assessee society is allowed for statistical purposes in terms of our aforesaid observations

Bench: Us:

Section 144 and 270A of the Income Tax Act, 1961 (for short “the Act”), respectively, for A.Y. 2020-21. As common issues are involved in the captioned appeals, therefore, the same are taken up and disposed of by this consolidated order. 2. We shall first take up the appeal filed by the assessee for A.Y. 2020-21 in wherein

THE SALUR GIRIJAN CO OP MARKETING SOCIETY LIMITED,VIZIANAGARAM vs. INCOME TAX OFFICER, WARD-1, VIZIANAGARAM

In the result, the appeal of the assessee society is allowed for statistical purposes in terms of our aforesaid observations

Bench: Us:

Section 144 and 270A of the Income Tax Act, 1961 (for short “the Act”), respectively, for A.Y. 2020-21. As common issues are involved in the captioned appeals, therefore, the same are taken up and disposed of by this consolidated order. 2. We shall first take up the appeal filed by the assessee for A.Y. 2020-21 in wherein

THE ANIGANDLAPADU PACS LTD,KRISHNA DIST vs. INCOME TAX OFFICER, WARD(1)1 VIJAYAWADA, VIJAYAWADA

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

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.300/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2020-21) The Anigandlapadu Pacs Ltd. Vs. Income Tax Officer 10-1, Anigandlapadu Village Ward-1(1) Penuganchiprolu Post Vijayawada Penuganchiprolu Mandal Krishna Dist. [Pan : Aacat7983Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

condone the delay and admit the appeal for hearing in the interest of justice. 3. Brief facts of the case are that the assessee is a cooperative society, provides credit facilities to it’s members i.e. sanction of crop loans out of deposits collected from it’s members. It also provides services i.e. supply of fertilisers and manures, marketing

KUNDERU PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD,KUNDERU vs. INCOME TAX OFFICER, WARD-2(4), VIJAYAWADA

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.219/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2017-18) The Kunderu Primary Agricultural Co- Vs. Income Tax Officer Operative Credit Society Ltd. Ward-2(4) D.No.3068, Kunderu, Vijayawada Kankipadu Mandal Krishna Dist [Pan : Aabat0643G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

condone the delay and admit the appeal for hearing. 3 I.T.A. No.219/Viz/2023, A.Y.2017-18 The Kunderu Primary Agricultural Co-operative Credit Society Ltd., Kunderu 3. Brief facts of the case are that the assessee is a Primary Agricultural Cooperative Society. Notice was issued to the assessee as the assessee had deposited cash of Rs.30,87,100/- in Krishna District Co-Operative

THE PAYAKARAOPETA WOMENS MUTUALLY AIDED CO OP THRIFT CREDIT SOCIETY LIMITED,PAYAKARAOPETA vs. ACIT, CIRCLE-5(1), VISAKHAPATNAM

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

Bench: the Tribunal. In respect of belated filing of the appeal, the Ld. Authorized Representative filed a petition along with an affidavit stating that due to inadvertent oversight in tracking the date, the appeal before the Tribunal was filed belatedly on 02nd June, 2025 instead of 31st May, 2025 resulting in a delay of 02 days. It was further submitted that the delay is neither intentional nor deliberate but solely due to human error and therefore pleaded that the delay of 02 days may be condon

condone the delay of 02 days in filing the appeal before the Tribunal and proceed to adjudicate case. 3. Brief facts of the case are that the assessee a cooperative society registered under Andhra Pradesh Mutually Aided Cooperative Societies Act, 1965. The assessee filed its return of income for the AY 2010-11 on 28/09/2010 declaring NIL income after claiming