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

7 days and hence prejudice is being caused due to non-adherence\nto the time period under section 148A(b) requires to be accepted. He pleaded\nthat in this case, assessee was issued notice on 22.03.22 to comply with it on\nor before 29.03.2022.\n\n10. Further Ld.AR also submitted that the Ld. AO has not provided the\nrelevant information

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 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

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

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

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

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

disallowance\nof interest under section 80P(2)(a)(i) of the Act consideringthe interest received\nfrom State Bank of India is not eligible for deduction u/s 80P(2)(a)(i) of the Act.\nOn this issue, Ld. Authorised Representative [hereinafter “Ld.AR”] relied on\nthe Coordinate Bench decision in the case of ITO v. The Kakateeya Mutually\nAided Thrift and Credit

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)

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

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

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

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)

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

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)

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

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)

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

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)

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

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)

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

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

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)

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

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)

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