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

Bench: Shri N.K. Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon'Ble

disallowed the deduction of Rs.97,88,434/- which was claimed by the Assessee u/sec. 80P(2)(d) of the Act. Against the said additions, the Assessee preferred the first appeal before the ld. CIT(A), who sustained the aforesaid additions, against which the Assessee preferred the instant appeal and raised two issues. (M/s. The Krishna District Milk Producers Mutually Aided

THE KRISHNA DISTRICT MILK PRODUCERS MUTUALLY AIDED CO-OPERATIVE UNION LIMITED,VIJAYAWADA vs. THE PR. COMMISSIONER OF INCOME TAX, , VIJAYAWADA

Bench: Shri N.K. Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon'Ble

disallowed the deduction of Rs.97,88,434/- which was claimed by the Assessee u/sec. 80P(2)(d) of the Act. Against the said additions, the Assessee preferred the first appeal before the ld. CIT(A), who sustained the aforesaid additions, against which the Assessee preferred the instant appeal and raised two issues. (M/s. The Krishna District Milk Producers Mutually Aided

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:

disallowance of Rs.10,31,752/- is upheld, and the 9 G MEDAPADU PACS vs. ITO appeal is dismissed. The addition made by the Assessing Officer stands confirmed. 5.3.8 The appellant has claimed commission income amounting to Rs.1,82,15,130/- received from The Andhra Pradesh State Civil Supplies Corporation Ltd., which has been treated by the Assessing Officer as business

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

SRI UMA KAMANDALESWARA CO - OPERATIVE RURAL BANK LTD.,ATHREYAPURAM vs. THE ADDL. CIT,, KAKINADA

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Blesri Uma Kamandaleswara Vs. Addl.Cit, Kakinada Co-Op Rural Bank Ltd., Ryali, Range, Kakinada. Athreyapuram Mandalm, East Godavari District. Pan No. Aadas 4663 B (Appellant) (Respondent)

disallowed by the Assessing Officer for deduction under section 80P(2)(a)(i). The Commissioner partly allowed the appeal holding that the interest income relatable to non-SLR investments would not qualify for exemption. The Tribunal allowed the appeal of the assessee holding that in respect of interest income arising both from SLR securities and from non-SLR securities, deduction

THE SRI GOWRI COOPERATIVE SOCIETY,VISAKHAPATNAM vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1,, VISAKHAPATNAM

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Blem/S. The Sri Gowri Vs. Pr.Cit-1, Co-Operative Society, Visakhapatnam. D.No.49-34-32/1, Konathala Complex, Akkayyapalem Main Road, Visakhapatnam. Pan No. Aaaat 8140 M (Appellant) (Respondent)

D E R PER V. DURGA RAO, JUDICIAL MEMBER This appeal by the assessee is directed against the order of Principal Commissioner of Income Tax-1, Visakhapatnam, dated 31/03/2017 for the Assessment Year 2012-13. 2. Facts of the case, in brief, are that assessee is a Co-operative society and had claimed a deduction u/sec. 80P(2

BHEEMUNIPATNAM MUTUALLY AIDED COOPERATIVE BUILDING SOCIETY LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

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. Nos. 175, 176 & 177/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2017-18, 2018-19 & 2020-21) Bheemunipatnam Mutually Aided V. Dcit / Acit, Circle – 3(1) Cooperative Building Society Limited Income Tax Office H.No. 10-36-284 Infinity Towers, Sankaramatam Road Bheemunipatnam – 531163 Visakhapatnam – 530016 Andhra Pradesh Visakhapatnam, Andhra Pradesh [Pan: Aaaat5114H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowance of interest under section 80P(2)(d) of the Act consideringthe interest received from a cooperative bank is not eligible for deduction u/s 80P(2)(d) of the Act. On this issue, Ld. Authorised Representative [hereinafter “Ld.AR”] submitted that the assessee is a cooperative society registered under the District Cooperative Officer, Visakhapatnam. Ld.AR further submitted that the assessee Page

BHEEMUNIPATNAM MUTUALLY AIDED COOPERATIVE BUILDING SOCIETY LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

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. Nos. 175, 176 & 177/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2017-18, 2018-19 & 2020-21) Bheemunipatnam Mutually Aided V. Dcit / Acit, Circle – 3(1) Cooperative Building Society Limited Income Tax Office H.No. 10-36-284 Infinity Towers, Sankaramatam Road Bheemunipatnam – 531163 Visakhapatnam – 530016 Andhra Pradesh Visakhapatnam, Andhra Pradesh [Pan: Aaaat5114H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowance of interest under section 80P(2)(d) of the Act consideringthe interest received from a cooperative bank is not eligible for deduction u/s 80P(2)(d) of the Act. On this issue, Ld. Authorised Representative [hereinafter “Ld.AR”] submitted that the assessee is a cooperative society registered under the District Cooperative Officer, Visakhapatnam. Ld.AR further submitted that the assessee Page

BHEEMUNIPETAM MUTUALLY AIDED COOPERATIVE BUILDING SOCIETY LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM

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. Nos. 175, 176 & 177/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2017-18, 2018-19 & 2020-21) Bheemunipatnam Mutually Aided V. Dcit / Acit, Circle – 3(1) Cooperative Building Society Limited Income Tax Office H.No. 10-36-284 Infinity Towers, Sankaramatam Road Bheemunipatnam – 531163 Visakhapatnam – 530016 Andhra Pradesh Visakhapatnam, Andhra Pradesh [Pan: Aaaat5114H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowance of interest under section 80P(2)(d) of the Act consideringthe interest received from a cooperative bank is not eligible for deduction u/s 80P(2)(d) of the Act. On this issue, Ld. Authorised Representative [hereinafter “Ld.AR”] submitted that the assessee is a cooperative society registered under the District Cooperative Officer, Visakhapatnam. Ld.AR further submitted that the assessee Page

NO 368 KOLAKALURU PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. INCOME TAX OFFICER, WARD-1, TENALI

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

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.456/Viz/2025 (िनधा"रण वष"/Assessment Year:2019-20) No.368 Kolakaluru Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-1, Credit Society Limited, Tenali. Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W Section 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated

disallowance of deduction claimed u/s 80P(2)(a)(i) of the Act. 4. Any other ground that may be urged at the time of appeal hearing." 2. Succinctly stated, the AO based on information disseminated in accordance with the Risk Management Strategy (RMS), which revealed that the assessee society had during the subject year made cash deposits/withdrawals aggregating

ACIT, (EXEMPTIONS), EXEMPTIONS CIRCLE,, VIJAYAWADA vs. SRI PRAKASH EDUCATIONAL SOCIETY,, TUNI,

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

13 for claiming exemptions. (See also Expln. (1) to Section 11(1).] (d) Section 11(1) (d) specifically grants exemption to capital contributions to make the fact of non-taxability clear beyond doubt. But it proceeds on the erroneous assumptions that such contributions are of income nature - "income in the form of voluntary contributions". This assumption should be disregarded

ACIT, EXEMPTIONS,, VIJAYAWADA vs. SRI PRAKASHA EDUCATIONAL SOCIETY,, TUNII

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

13 for claiming exemptions. (See also Expln. (1) to Section 11(1).] (d) Section 11(1) (d) specifically grants exemption to capital contributions to make the fact of non-taxability clear beyond doubt. But it proceeds on the erroneous assumptions that such contributions are of income nature - "income in the form of voluntary contributions". This assumption should be disregarded

ACIT,, VIJAYAWADA vs. SRI PRAKASH EDUCATIONAL SOCIETY, TUNI

In the result, all the appeals filed by the revenue for the

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

13 for claiming exemptions. (See also Expln. (1) to Section 11(1).] (d) Section 11(1) (d) specifically grants exemption to capital contributions to make the fact of non-taxability clear beyond doubt. But it proceeds on the erroneous assumptions that such contributions are of income nature - "income in the form of voluntary contributions". This assumption should be disregarded

INCOMETAX OFFICER, WARD-3(1), VISAKHAPATNAM vs. SURENDRA NATH GUBBALA, VISAKHAPATNAM

Bench: Us:

D E R ""त रवीश सूद, जे.एम./PER RAVISH SOOD, J.M. The present appeal filed by the revenue is directed against the order passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 30.09.2024, which in turn arises from the order passed by the Assessing Officer (for short, “A.O.”) under Section

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 ELURU CO OPERATIVE HOUSE MORTGAGE SOCIETY LTD,ELURU vs. INCOME TAX OFFICER , ELURU

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.10/Viz/2024 (िनधा"रण वष" / Assessment Year : 2018-19) The Eluru Cooperative House Vs. Income Tax Officer, Mortgage Society Limited, Eluru. Eluru. Pan: Aacat0060G (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri C. Subrahmanyam, Ar ""याथ" क" ओर से / Respondent By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 23/07/2024 घोषणा क" तारीख/Date Of : 26/07/2024 Pronouncement O R D E R

disallowing the claim made by the assessee U/s. 80P(2)(a)(i) of the Act. We have perused the ratio laid down by the Hon’ble Apex Court in the case of M/s. Totgars Cooperative Sale Society Ltd (supra) and found that in that case the society is engaged in marketing of the agricultural produce by its members

THE ANDALURU LARGE SIZE CO-OPERATIVE SOCIETY ANADALURU,ANDALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJAHMUNDRY

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.58/Viz/2024 (निर्धारण वर्ा / Assessment Year : 2018-19) The Andaluru Large Size Co- Vs. The Asst. Commissioner Of Operative Society Andaluru, Income Tax, D. No. 3-77, Main Road, Circle-1, Andaluru, West Godavari Dist, Rajahmundry. Andhra Pradesh – 534238. Pan: Aacat 1978 M (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थी की ओर से/ Appellant By : Sri Gvn Hari, Ar प्रत्यधर्थी की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख / Date Of Hearing : 21/03/2024 घोर्णध की तधरीख/Date Of : 27/03/2024 Pronouncement O R D E R Per Duvvuru Rl Reddy:

disallowing the claim made by the assessee U/s. 80P(2)(a)(i) of the Act. We have perused the ratio laid down by the Hon’ble Apex Court in the case of M/s. Totgars Cooperative Sale Society Ltd (supra) and found that in that case the society is engaged in marketing of the agricultural produce by its members

THE INDUPALLI PRIMARY AGRICULTURE CO OPERATIVE CREDIT SOCIETY LTD,UNGUTURU MANDALAM vs. INCOME TAX OFFICER, WARD-1, GUDIWADA

In the result, appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.88/Viz/2024 & 89/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2018-19 & 2020-21) The Indupalli Primary Agriculture Vs. Income Tax Officer Cooperative Credit Society Ltd., Ward-1 No.Kr356 Dno.5-46, Indupalli Village Gudiwada Indupalli Post Unguturu Mandalam Krishna [Pan : Aacat9205B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowing the claim made by the assessee U/s. 80P(2)(a)(i) of the Act. We have perused the ratio laid down by the Hon’ble Apex Court in the case of M/s. Totgars Cooperative Sale Society Ltd (supra) and found that in that case the society is engaged in marketing of the agricultural produce by its members