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.

D E R PER MANJUNATHA G., A.M : This appeal filed by the assessee is directed against the order of the learned Addl/Joint Commissioner of Income Tax 2 (Appeals) - 4, Chennai (for short “Ld.CIT(A)”) relating to the assessment year 2017-18. 2. At the outset, there is a delay of 69 days in filing the appeal before the Tribunal

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

section 80P but remanded the matter back to the jurisdictional Assessing Officer to allow proportionate expenses incurred for earning the income after affording the assessee an opportunity of hearing and after verifying the same with documentary evidence. The Ld. CIT(a) has not decided the issue of mistake of business income in the computation sheet. 7. The ITO, Ward

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

condone the delay of 98 days in filing the appeal of the assessee before the Tribunal and proceed to adjudicate the appeal on merits. 4. Briefly stated the facts of the case are that the assessee, The Farmers Service Cooperative Limited, is a primary agricultural Credit Cooperative Society established with the object of providing loans for agricultural purpose

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

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 That

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)

D E R PER SHRI S BALAKRISHNAN, ACCOUNTANT MEMBER: 1. This appeal is filed by the assessee against order of Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter in short “Ld. CIT(A)”] vide DIN & Order No. ITBA/NFAC/S/250/2023- 24/1060602731(1) dated 07.02.2024 for the A.Y. 2017-18 arising out the order I.T.A.No.199/VIZ/2024 The P.A.C.S

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)

D E R PER SHRI S BALAKRISHNAN, ACCOUNTANT MEMBER: 1. This appeal is filed by the assessee against order of Learned Commissioner of Income Tax (Appeals)/Addl/JCIT (A)-2, Coimbatore, [hereinafter in short “Ld.CIT(A)”] vide DIN & Order No. I.T.A.No.439/VIZ/2024 The Vazrapukotturu Primary Agricultural Cooperative Credit Society Limited ITBA/APL/S/250/2023-24/1062944245(1) dated 19.03.2024 for the A.Y.2018-19 arising

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

D E R PER DUVVURU RL REDDY, Judicial Member : This appeal is filed by the assessee is against the order of the Ld. CIT(A)-NFAC, Delhi in DIN & Order No. ITBA/NFAC/S/250/2021-22/1038084944(1), dated 24/12/2021 arising out of the order passed U/s. 144 of the Income Tax Act, 1961 [the Act] for the AY 2017-18. 2. At the outset

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

D E R PER DUVVURU RL REDDY, Judicial Member : This appeal is filed by the assessee is against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“Ld. CIT(A)-NFAC”] vide DIN & Order No. ITBA/NFAC/S/250/2023-24/1063641657(1), dated 29/03/2024 arising out of the order passed U/s. 144 of the Income

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:

D E R प्रनत रवीश सूद, जे.एम./PER RAVISH SOOD, J.M. The captioned appeals filed by the assessee society are directed against the respective orders passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 17.12.2024 and 12.12.2024, which in turn arises from the respective orders passed by the Assessing Officer under Section

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:

D E R प्रनत रवीश सूद, जे.एम./PER RAVISH SOOD, J.M. The captioned appeals filed by the assessee society are directed against the respective orders passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 17.12.2024 and 12.12.2024, which in turn arises from the respective orders passed by the Assessing Officer under Section

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

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)

D E R Per Shri Duvvuru RL Reddy, Judicial Member : Condonation of Delay : This appeal is filed by the assessee against the order of Commissioner of Income Tax (Appeals) [CIT(A)], National Faceless Appeal Centre (NFAC), Delhi in DIN & Order No. ITBA/NFAC/S/250/2023-24/1055304612(1) dated 22.08.2023, arising out of order passed u/s 147 r.w.s.144C of the Income

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)

D E R Per Shri Duvvuru RL Reddy, Judicial Member : Condonation of Delay : This appeal is filed by the assessee against the order of Commissioner of Income Tax (Appeals) [CIT(A)], National Faceless Appeal Centre (NFAC), Delhi in DIN & Order No.ITBA/ NFAC/S/250/2023-24/1052422378(1) dated 28.04.2023, arising out of order passed u/s 143(3) of the Income

SAGARA VIKASA MUTUALLY AIDED COOP THRIFT SOCIETY LTD ,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-2(1), VISAKHAPATNAM

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

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.235/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2018-19) Sagara Vikasa Mutually Aided Coop Vs. Income Tax Officer Thrift Society Ltd., Ward-2(1) Opp. Sun School Visakhapatnam Near Vuda Layout, Bheemunipatnam Visakhapatnam [Pan : Aacas9620H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

D E R Per Shri Duvvuru RL Reddy, Judicial Member : This appeal is filed by the assessee against the order of Commissioner of Income Tax (Appeals) [CIT(A)], National Faceless Appeal Centre (NFAC), Delhi vide DIN & Order No.ITBA/NFAC/S/250/2022-23/1046186894(1) dated 06.10.2022 for the Assessment Year (A.Y.) 2018-19. 2 I.T.A. No.235/Viz/2022, A.Y.2018-19 Sagara Vikasa Mutually aided Coop Thrift Society