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

disallowance\nof interest under section 80P(2)(d) of the Act consideringthe interest received\nfrom a cooperative bank is not eligible for deduction u/s 80P(2)(d) of the Act.\nOn this issue, Ld. Authorised Representative [hereinafter “Ld.AR"] submitted\nthat the assessee is a cooperative society registered under the Registrar of\nCooperative Societies, Government of AP. Ld.AR further submitted that

GMEDAPADU PACS,GMEDAPADU vs. ITO, WARD-1, KAKINADA

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.574/Viz/2025 ("नधा"रण वष"/Assessment Year: 2020-21) G Medapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Sri Kss Sarma, Ca राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 16/10/2025 Hearing: घोषणा क" तार"ख/Date Of 14/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

10,31,752. 4. Apropos the paddy procurement commission, the AO was of the view that as the same was received by the assessee society from a non- member, thus, the same was ineligible for deduction under section 80P(2)(a)(iii) of the Act. The AO was, further of the view that the interest income earned by the assessee

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.

10. The learned counsel for the assessee Shri K. Siva Rama Kumar, C.A. submitted that the Ld. CIT(A) erred in sustaining the addition made by the A.O. towards disallowance of deduction under Section 80P(2

INCOME TAX OFFICER, BHIMAVARAM vs. THE YENDAGANDHI LARGE SIZE COOPERATIVE SOCIETY LIMITED, YEDAGANDI

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.354/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) Income Tax Officer - Ward - 1 V. The Yendagandhi Large Size Cooperative Society Limited Opp. Ganesh Canteen 4-16, Kk Road, Yendagandhi J.P. Road, Bhimavaram – 534202 West Godavari District – 534186 Andhra Pradesh Andhra Pradesh [Pan: Aacat0967G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 80P(2)(a) of the Act. We therefore by respectfully following the jurisdictional High Court are of the view that interest income should be allowed as deduction U/s. 80P(2)(a)(i) of the Act and thereby the Ld. CIT(A)- NFAC has rightly held by deleting the addition made by the Ld. AO and hence we find

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

VISAKHAPATNAM PORT AUTHORITY, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. CIT.,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, , VISAKHAPTNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

THE VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASST. CIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

section 2(15) of the Act,the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further, the registration U/s. 12AA of the Act was 51 cancelled w.e.f1/4/2009. The assessee filed its return of income for the AY 2011-12 admitting a total income of Rs. 2,10

SREE SHANTINATH MUNISUVARAT SWAMY RAJENDRA SURI JAIN TRUST,TANUKU vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), HYDERABAD, TANUKU

disallowed the claim of the appellant\nin accordance with the provisions of Section 80A(5) of the Act. It is further\nsubmitted that in accordance with the provisions of Section 80A(5) of the\nAct, where the assessee fails to make a claim in his return of income for\nany deduction under section 10A or section 10AA or section

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA vs. THE KRISHNA DISTRICT MILK PRODUCERS MUTUALLY AIDED CO OP UNION LIMITED, VIJAYAWADA

disallowance of deduction_u/s.80P(2)(d) of the Act, without\nconsidering the Supreme Court decision in the case of M/s. Totgars\nPage. No 4\nCooperative Sale Society Limited (322 ITR 283), wherein it was held that\nthe interest income earned on investment of surplus funds which are not\nimmediately required for business purposes, is taxable under the head\n'Income

AP POLLUTION CONTROL BOARD,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX, EXEMPTION CIRCLE, VIJAYAWADA

In the result, appeal filed by the assessee is allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.298/Viz/2025 (िनधा"रण वष"/Assessme298Nt Year: 2021-22) Andhra Pradesh Pollution Vs. Dy. Cit Control Board, (Exemption Circle) Vijayawada Vijayawada Pan:Aaaja1610Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Satyanarayana Murthy, Ca राज" व "ारा/Revenue By:: Dr. Satyasai Rath, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 30/07/2025 घोषणा की तारीख/Pronouncement: 06/08/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Revision Order Dated 11/03/2025 Of The Learned Cit (Exemptions), Passed U/S 263 Of The Act For The A.Y.2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeal:

disallowance will increase the total income, and such increased total income will be exempt u/s 10(46). vi) The assessee has also explained that approval dated 29.9.2010 u/s 10(23C) [copy enclosed as Attachment-2] was cancelled with effect from 8th March, 2017, the date on Page 10 of 18 ITA No 298 of 2025 AP Pollution Control Board Vijayawada

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

10. From the bare reading of section 80P(2)(a) of the Act, the whole of\namount of profits and gains of the business attributable to one or more of\nsuch activities shall be allowed as a deduction. Further, section 80P(2)(d)\nand 80P(2)(e) of the Act also allows similar deductions. It is clear that the\ndeductions