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

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:

7 G MEDAPADU PACS vs. ITO banking function. Rather, it is derived from the passive deployment of funds not immediately required for business purposes. 5.3.2 Section 80P(2)(a)(i) provides deduction to a co-operative society engaged in the business of banking or providing credit facilities to its members. In this case, however, the interest income does not arise

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

7. In this appeal, the Assessee has challenged the order passed by the ld. CIT(A) against the affirmation of additions qua grants-in-aid received by the Assessee society as capital in nature and disallowance of deduction claimed u/sec. 80P(2)(d) of the Act. 8. Brief facts of the case are that the AO while following the directions

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

7. In this appeal, the Assessee has challenged the order passed by the ld. CIT(A) against the affirmation of additions qua grants-in-aid received by the Assessee society as capital in nature and disallowance of deduction claimed u/sec. 80P(2)(d) of the Act. 8. Brief facts of the case are that the AO while following the directions

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.

7 dt.10.06.2025 wherein under identical set of facts, the deduction claimed under Section 80P(2)(a)(i) of the Act, was allowed. 11. The learned counsel for the Revenue, on the other hand, supporting the order of the Ld. CIT(A) submitted that, as per the terms of Section 80AC, read with Section 80A(5), filing the return of income

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)

7 I.T.A.No.354/VIZ/2024 C.O. No. 14/VIZ/2024 The Yendagandhi Large Size Cooperative Society Limited 9. Respectfully following the decision of the Co-ordinate Bench, we are of the considered view that interest income earned from cooperative bank were allowable as deduction under section 80P(2)(d) of the Act and we do not find any reason to interfere with the findings

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

2(24) of the Act and accordingly, we uphold the order of the CIT(A) and dismiss the appeal of the revenue. M/s. Sri Prakash Educational Society, Tuni 7. The next issue in revenue’s appeal is addition u/s 40(ba) of the Act. During the previous year relevant to the assessment year, the assessee has paid the salaries

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

2(24) of the Act and accordingly, we uphold the order of the CIT(A) and dismiss the appeal of the revenue. M/s. Sri Prakash Educational Society, Tuni 7. The next issue in revenue’s appeal is addition u/s 40(ba) of the Act. During the previous year relevant to the assessment year, the assessee has paid the salaries

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

2(24) of the Act and accordingly, we uphold the order of the CIT(A) and dismiss the appeal of the revenue. M/s. Sri Prakash Educational Society, Tuni 7. The next issue in revenue’s appeal is addition u/s 40(ba) of the Act. During the previous year relevant to the assessment year, the assessee has paid the salaries

MANNE SUBBA RAO,RAJAMAHENDRAVARAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), , RAJAMAHENDRAVARAM

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

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.158/Viz/2018 (धििाारण िर्ा/ Assessment Year: 2014-2015) Manne Subba Rao Acit, Circle-2(1) D.No.78-15-21/5,T-1, Rajamahendravaram Block-1, Rama Residency Syamala Nagar Rajamahendravaram [Pan : Ayyps 3433R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलार्थी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यार्थी की ओर से/ Respondent By : Smt. Suman Malik, Dr

disallowing the loss. For the sake of clarity, we extract the relevant part of the order of the Ld.CIT(A) available in page No.4 para 5.3 to 5.5. which reads as under : “5.3. It is clear from the above that the core issue in this appeal is whether Section 45(2) of the Act is applicable in this case

M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,ELURU vs. THE ITO, WARD-2, ELURU, ELURU

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

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

section 40A(7)(b) of the Act the A.O., reopened the assessment and issued notice u/s 148 of the Act, which is challenged by the assessee. The Ld. CIT (A) upheld the issue of notice u/s 148 of the Act. The facts of the assessee’s case are similar to that of in appeal No.49

M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,ELURU vs. THE ITO, WARD-2, ELURU, ELURU

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

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

section 40A(7)(b) of the Act the A.O., reopened the assessment and issued notice u/s 148 of the Act, which is challenged by the assessee. The Ld. CIT (A) upheld the issue of notice u/s 148 of the Act. The facts of the assessee’s case are similar to that of in appeal No.49

THE ACIT., CIRCLE - 1, ELURU, ELURU vs. M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,, ELURU

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

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

section 40A(7)(b) of the Act the A.O., reopened the assessment and issued notice u/s 148 of the Act, which is challenged by the assessee. The Ld. CIT (A) upheld the issue of notice u/s 148 of the Act. The facts of the assessee’s case are similar to that of in appeal No.49

THE ITO, WARD-2, ELURU, ELURU vs. M/S THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD., ELURU

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

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

section 40A(7)(b) of the Act the A.O., reopened the assessment and issued notice u/s 148 of the Act, which is challenged by the assessee. The Ld. CIT (A) upheld the issue of notice u/s 148 of the Act. The facts of the assessee’s case are similar to that of in appeal No.49

THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,,ELURU vs. THE ACIT,, VISAKHAPATNAM

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

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

section 40A(7)(b) of the Act the A.O., reopened the assessment and issued notice u/s 148 of the Act, which is challenged by the assessee. The Ld. CIT (A) upheld the issue of notice u/s 148 of the Act. The facts of the assessee’s case are similar to that of in appeal No.49

THE DISTRICT CO-OPERATIVE CENTRAL BANK LTD.,,ELURU vs. THE ACIT,, ELURU

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

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

section 40A(7)(b) of the Act the A.O., reopened the assessment and issued notice u/s 148 of the Act, which is challenged by the assessee. The Ld. CIT (A) upheld the issue of notice u/s 148 of the Act. The facts of the assessee’s case are similar to that of in appeal No.49

THE ACIT,, ELURU vs. M/S. THE DISTRICT CO - OPERATIVE CENTRAL BANK LTD., ELURU

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

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

section 40A(7)(b) of the Act the A.O., reopened the assessment and issued notice u/s 148 of the Act, which is challenged by the assessee. The Ld. CIT (A) upheld the issue of notice u/s 148 of the Act. The facts of the assessee’s case are similar to that of in appeal No.49

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)

7. Disallowance of excess claim of depreciation on capital 5,20,74,400 dredging as per para 4.0 to 4.7 8. Disallowance of excess claim of depreciation on railway 2,60,35,204 permanent way as per para 5.0 to 5.4 9. Upfront premium / unexpired discounts added as 13,77,54,997 income as per para