TaxTMI 
TaxTMI 
2024 (7) TMI 1650
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....ice and the order passed u/s 263 of the Act and hence the impugned order is bad in law. 2. The learned Principal Commissioner of income-tax - 1, Rajkot, erred in setting aside the assessment order framed u/s 143(3) of the Act, by holding that the A.O. did not conduct any inquiries in respect of eligibility of deduction of interest and dividend income earned from Co-operative Bank, claimed by the Assessee u/s 80P(2)(d) of the Act. 3. The learned Principal Commissioner of Income-tax - 1, Rajkot, failed to appreciate that the impugned issue was duly examined by the assessing officer by way of specific inquiry/notice and reply thereto, while finalizing assessment proceedings u/s 143(3) of the Act. 4. The assessee craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal." Facts of assessee's case 2. Brief facts, as discernible from the orders of lower authorities are that assessee before us, is a Co-operative Society, and engaged in the business of providing credit facilities to the member of the society. The assessee had filed return of income for assessment year(AY) 2018-19, on 13.08.2018, declaring t....
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.... by a co-operative society are contained in section 80P(2)(d) of the Income tax Act, 1961, which read as under: "in respect of any income by way of interest or dividends derived by the co- operative society from its investments with any other co-operative society, the whole of such income" On plain reading of the above provision, it is clear that the section refers to interest and dividends earned from investments in another co-operative society only. Thus, this deduction cannot be extended to the interest income earned from the investment in any co- operative bank. It is pertinent to note here that vide Finance Act, 2006, deduction from income of Co-operative banks as per the provision of section 80P of the Act, has been withdrawn by way of insertion of section 80P(4) of the I. T. Act, 1961, w. e. f. 01.04.2007 which differentiate a cooperative bank in. "comparison to co-operative society. The co- operative banks are functioning at par with the other commercial banks, which do not enjoy any tax benefit. Therefore section 80P of the Income tax Act was amended by inserting a new sub section (4) so as to provide that the provisions of the said section shall not appl....
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....revenue receipt, eligible to tax. Hence, keeping surplus funds in co-operative bank is not falling under concept of mutuality and interest earned on such deposits are not eligible for deduction u/s 80P(2)(d). Reliance is placed on the decision of Hon'ble Karnataka High Court in the case of Principal CIT, Hubballi Vs Totagars Co.Op. Sale Society 83 taxmann.com 140 (dt. 16/06/.2017) wherein it was held that Interest or dividend earned by assessee, a co- operative society, marketing members' agriculture product, from surplus deposits kept with a co-operative bank, was not eligible for deduction under section 80P(2)(d). Further, the review petition filed in the above case was also dismissed by the Hon'ble Karnataka High Court dated 22/09/2017. In the findings of the High Court of Gujarat in SCA No. 20585 of 2019 dated 4/01/2022 in the case of Katlary Kariyana Merchant Sahkari Sarafi Mandali Ltd. Vs. ACIT, Himmatnagar, it is reiterated that the Assessing Officer has rightly formed opinion while reopening the Assessment u/s 147 of the Income Tax Act, 1961, that the Interest derived from the surplus funds invested by the assessee in the nature of FDRs ot....
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....he interests of the revenue. In this case deduction u/s. 80P(2)(d) of the Income tax Act has been allowed to the you which in view of the facts discussed herein above paras is erroneous & prejudicial to the interests of the revenue. The deduction to the extent of Rs. 16,52,694/- has been allowed without inquiring into the claim. Therefore in view of the above, the assessment order is erroneous and prejudicial to the interest of revenue. 5. In view of the above and in the light of facts and circumstances of the case. the order passed by the AO u/s 143(3) r.w.s. 143(3A) & 143(3B) of the IT Act for A.Y 2018- 19 on 19/01/2021 being erroneous and prejudicial to the interest of revenue and therefore needs to be revised u/s 263 of the IT Act. Therefore, I hereby initiate proceedings u/s 263 of the Act with a view to pass a suitable order. Before passing of such order, you are hereby given an opportunity of being heard in the matter. In this connection you are requested to furnish your reply / submission / explanation or objection if any by mail address id [email protected]/ speed post to this office on or before 17-01-2023." 4. In response to the above show -ca....
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....our of assessee [Bajaj Tempo Limited, Bombay vs CIT (1992) 3 SCC 78]. In view of above, considering the above submissions and binding case law, it was submitted that assessee's claim of Rs. 16,52,694/-u/s 80P(2)(a)(i) is justified. Findings of Learned Principal Commissioner of Income Tax: 5. However, Ld. PCIT rejected the contention of the assessee and noted that as per the relevant provisions of Section 80P(2)(d) of the Act, the assessee society is not eligible to claim the deduction, in respect of interest income received from Co-operative banks, on account of fixed deposit made by the assessee with the said bank. Ld. PCIT then referred the provisions of section 80P(2)(d), of the Act, which reads as follows: "80P.(1) Where, in the case of an assessee being a co-operative society, the gross total income includes any income referred to in sub-section (2), there shall be deducted, in accordance with and subject to the provisions of this section, the sums specified in sub-section (2), in computing the total income of the assessee. (2) The sums referred to in sub-section (1) shall be the following,namely : (a) in the case of a co-operative society....
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.... cooperative bank in "comparison to co-operative society". The co- operative banks are functioning at par with the other commercial banks, which do not enjoy any tax benefit. Therefore, section 80P of the Income tax Act was amended by inserting a new sub section (4) so as to provide that the provisions of the said section shall not apply in relation to any co-operative bank other than a primary agricultural credit Society or a primary cooperative agricultural and rural development bank. The legislative intent of distinguishing the Co-operative banks from the Co-operative societies is very clear from the below part of speech given by the then Union minister of Finance Shri P. Chidambaram on 28-02-2006 presenting the budget and proposing the said amendment; "XIV Tax Proposals- direct Taxes 166. Co-operative banks, like any other bank are lending institutions and should pay tax on their profits." Further, the PCIT noted that the exemption and the deduction clauses of the Act, cannot be interpreted liberally. The Hon'ble Apex Court rendered in the case of Union of India v. Wood Papers Ltd (AIR 1991 SC 2049) and Hon'ble Andhra Pradesh High Court in the case ....
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....riyana Merchant Sahkari Sarafi Mandali Ltd (supra) is direct on issue and this is later decision of Jurisdictional High Court, which clearly explains the provisions of Section 80P(2)(d) of the Act. The old decisions relied upon by assessee, has not dealt with the ratio laid down by Hon'ble High Court, in the case of Katlary Kariyana Merchant Sahkari Sarafi Mandali Ltd (supra), hence ratio of such decisions cannot be made applicable. 8. The Ld. PCIT further noted that with effect from 01/06/2015, Explanation - 2 to the section 263(1) has been inserted by which scope of section 263 of the Act has been expanded by incorporating the concept of "deemed to be erroneous". The same is reproduced as under: Explanation 2.-For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Commissioner or Commissioner, - (a) The order is passed without making inquiries or verification which should have been made; (b) The order is passed allowing any relief without inquiring into the claim; ....
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....(Gujarat)wherein it had upheld the opinion of the Assessing Officer that the interest derived from surplus funds invested by assessee in nature of FDRs in Co-operative Banks and Nationalized Bank, other than Co-operative Societies, will certainly not fall in category to be entitled to claim deductions under section 80P(2)(a)(i) and section 80P(2)(d) of the Act and thus have escaped assessment and will constitute Mistake apparent from record, rectifiable under section 254(2), as per the Hon'ble Supreme Court decision cited (supra), therefore, in the assessee's case under consideration, the order passed by the assessing officer, will certainly erroneous and prejudicial to the interest of the revenue. The Ld. PCIT had held that the assessment order passed by the Assessing Officer u/s 143(3) of the Act, dated 19.01.2021, is erroneous and prejudicial to the interest of the Revenue. Therefore, ld PCIT set aside the order u/s 143(3) of the Act, dated 19.01.2021, on the issues discussed above and directed the Assessing Officer to pass a fresh assessment order after denying deduction u/s 80P(2)(d), on Fixed Deposit interest income earned of Rs. 16,52,694/- from Co-operative bank 'Amrel....
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....f the Act, should not be subject matter of revision proceedings under section 263 of the Act. 11. The Ld. Counsel submitted that during the assessment proceedings, the Assessing Officer issued notice under section 142(1) of the Act, dated 16.11.2020, which is placed in paper book page no. 15, wherein the Assessing Officer especially asked the assessee on eligibility criteria of deduction claimed under section 80P(2)(d) of the Act. In response to the said notice of the Assessing Officer, the assessee has submitted the reply before the Assessing Officer, (vide reply dated 01.12.2020, of the assessee on page no.17 of paper book). The assessee stated in its reply that it has received interest income on fixed deposits/ or on investments from Co-operative bank the tune of Rs. 18,41,436/-, and dividend income of Rs. 52,350/-, (vide paper book page no.19). 12. The Ld. Counsel contended that although the assessee has not claimed the deduction under section 80P(2)(d) of the Act, to the tune of Rs. 16,52,694/-, however the Assessing Officer during the assessment proceeding was aware about this figure and the assessee has submitted before the Assessing Officer that it has ....
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....the case; and ld PCIT taking a different view by interpreting the same set of facts, differently, is not permissible u/s 263 of the Act. The reliance was placed by ld Counsel on the following decisions, viz: (i)Shreeji Prints (P.) Ltd. (2021) 130 taxmann.com 294 (SC) - Page 41-45,(ii)Kutch District Co-op. Milk Producers' Union Ltd. (2024) 159 taxmann.com 347 (Rajkot Trib),(iii)Kansara Popatlal Tribhuvan Metal (P.) Ltd., (2023) 156 taxmann.com 433 (Guj - HC).Thus, ld Counsel contended that as majority of decisions are favoring to the assessee and the decision in the case of Katlary Kariyana (supra) is distinguishable on facts, and hence the majority decisions of Jurisdictional High Court should be followed and preferred, at least, until and unless earlier decisions are overruled by a larger Bench, which is not so at present. The ld Counsel also relied on the judgment of Hon'ble Supreme Court in the case of Vegetable Products (1973) 88 ITR 192 (SC) wherein it was held even if two views are possible, the one that favours the assessee should be adopted. Therefore, ld. Counsel stated that order passed by the assessing officer is neither erroneous nor prejudicial to the interest of r....
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....ayana Merchant Sahkari Sarafi Mandali Ltd, 140 Taxmann.com 602 (Guj)wherein it was held that interest from cooperative banks and other banks are not eligible for deduction u/s 80P(2) (d) of the Act. Therefore, the Ld PCIT has rightly exercised his jurisdiction, as per clause (d) of explanation-2 of section 263 of the Act. 15. Therefore, Ld. CIT-DR contended that the deduction under section 80P(2)(d) of the Act is not allowable, on account of interest received from fixed deposits from co-operative bank, and therefore, view taken by the assessing officer is not legally sustainable in the eye of law. The Ld. DR for the Revenue heavily relied on the judgement of Hon'ble Gujarat High Court in the case of Katlary Kariyana (2022) 215 DTR 0125 (Guj), and also relied on the order of the Coordinate Bench of ITAT- Rajkot in the case of Lodhika Seva Sahkari Mandali, vide ITA No. 184/RJT/2022, order dated 05.04.2024 and stated that deduction under section 80P(2) (d) of the Act is not available in respect of interest income received from fixed deposit from a cooperative bank, therefore order passed by the assessing officer is erroneous as well as prejudicial to the interest of the Revenu....
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.... (2022) 327 CTR 0138 (Guj.), wherein the Hon'ble Gujarat High Court clearly stated that assessee is not eligible for deduction under section 80P(2)(d) of the Act in respect of interest received from co-operative bank. Thereafter, Ld. CIT-DR for the Revenue heavily relied on the judgment of the Coordinate Bench of ITAT, Rajkot in the case of Lodhika Seva Sahakari Mandali vs. PCIT, in ITA No. 184/Rjt/2022 for AY. 2017-18, order dated 05.04.2024 and stated that the jurisdictional Co-ordinate Bench of Rajkot in the above case has considered the judgement of Hon'ble Gujarat High Court in the case of Katlary Kariyana (supra),140 taxmann.com 602 (Guj.). Therefore, Ld. CIT-DR contended that the issue is squarely covered in favour of Revenue by the judgment of jurisdictional High Court of Gujarat in the case of Katlery Kariyana (supra) and by the decision of jurisdictional ITAT, Rajkot in the case of Lodhika Seva Sahakari Mandli (supra). 19. The ld. DR for the revenue, again reiterated the argument advanced by him and stated that it is important to note that Hon'ble Gujarat High Court in the case of Katlary Kariyana (supra), has approved the decision of Hon'ble Karnataka High Court ....
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....t Jilla Sahakari Kharid Vechan Sangh, in ITA Nos. 49/Rjt/2022, order dated 09.08.2023, and stated that Tribunal has reached its conclusions with respect to the decision of Hon'ble Gujarat High Court in case of State bank of India Vs. CIT (2016) 389 ITR 578 (Guj), but has not taken into consideration the decision of Katlary Kariyana (supra)issued before the date of passing this order, thereby rendering the decision sub-silentio and hence per-incurium. The ld. DR pointed out that in the judgment in case of Katlary Kariyana (supra), the Hon'ble High Court of Gujarat has discussed and distinguished the decision in case of State bank of India (supra), vis -a -vis amendment in the Income Tax Act, 1961. Thus, this decision of Tribunal in the case of Rajkot Jilla Sahakari Kharid Vechan Sangh(supra), contains a 'mistake apparent on record'. The ld.CIT-DR further pointed out that in this decision, the Tribunal referred the decision in the case of Surat Vankar Sahakari Sangh Ltd. (supra)which deals with assessment years(AY) 1991-92 to 1994, and this judgment does not deal with the reasoning adopted by Hon'ble Gujarat High Court in post amendments brought by Finance Act, 2015, in ....
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....h 2023, is correct, which may be upheld. Analysis and Conclusion 23. We have heard both the parties and carefully gone through the submissions put forth on behalf of the assessee along with the documents furnished and the case laws relied upon, and perused the facts of the case including the findings of the ld. PCIT and other material brought on record. We note that during the assessment proceedings, the Assessing Officer issued notice under section 142(1) of the Act, dated 16.01.2020, which is placed at paper book page no.15, wherein the Assessing Officer has especially asked the assessee, to furnish eligibility criteria of deduction claimed in different sections of Chapter VI-A, especially under section 80P(2)(a)(i) and under section 80P(2)(d) of the Act. The assessing officer, has also asked the assessee to furnish the documentary evidence in support of its claim of deduction under Chapter VI-A. In response to the said notice under section 142(1) of the Act, the assessee has submitted its reply, dated 01.12.2020 (vide paper book page nos. 17 to 21),before the Assessing Officer, the relevant part of the assessee's reply dated 01.12.2020, is reproduced below: From the abo....
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....019 on the following issues: S. No. Issues i. Investments/Advances/Loans ii. Unsecured Loans iii. Deduction from Total Income under Chapter VI-A The assessee society has filed Return of Income for AY. 2018-19 on 13.08.2018, vide acknowledgment no.108456181130818, reflecting Gross Total Income Rs. 43,36,723/- and after claiming deduction u/s 80P(2) of the I.T. Act, 1961 Returned income is declared NIL. The same is processed u/s 143(1) of the Income Tax Act, 1961 (hereinafter mentioned Act). 2. Notice u/s 143(2) of the Act issued on 22.09.2019 and thereafter notices u/s 142(1) of the Act along with questionnaire were issued. 3. In response to the notices issued, the assessee society has furnished all the relevant details called for. The same has been perused carefully and found to be in order. 4. In view of the above facts of the case and after considering the details furnished, the total income returned by the assessee is accepted." 26. From the above assessment order, it is vivid with that during the assessment proceedings, the assessing officer issued notice under section 142(1) of the Act, dated 16.11.2020,....
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.... Revenue stated that in the assessee's case under consideration, assessing officer cannot take a plausible view specially when there is a judgement of Hon'ble Gujarat High Court in the case of Katlary Karyana Merchant Sahkari Sarafi Mandali Ltd. (2022) 140 taxmann.com 602 (Gujarat), wherein it was held that interest received from co-operative banks and other banks are not eligible for deduction u/s. 80P(2)(d) of the Act. The reason being, the assessing officer ignored the judgement of the jurisdictional High Court of Gujarat, in the case of Katlary Karyana (Supra). Therefore, ld. D.R. stated that the order passed by the assessing officer is not sustainable in the eyes of law and hence the ld. PCIT has rightly exercised his jurisdiction as per clause (d) of explanation 2 of section 263 of the Act. Therefore, as per ld. DR. for the Revenue the order passed by the assessing officer is erroneous as well as prejudicial to the interest of the Revenue. We note that arguments advanced by the ld. D.R. for the Revenue carries weight and he has rightly stated that order passed by the assessing officer is not sustainable in the eyes of law. We also agree that during the assessment proceedings ....
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....ne of the courses permissible in law and it has resulted in loss to the revenue, or where two views are possible and the Assessing Officer has taken one view with which the CIT does not agree, it cannot be treated as an erroneous order prejudicial to the interest of the revenue "unless the view taken by the Assessing Officer is unsustainable in law". 30. Taking note of the aforesaid dictum of law laid down by the Hon'ble Apex Court, let us examine the issue under consideration. We agree with the ld. D.R. for the Revenue that just to collect the details during the assessment proceedings by issuing notice 142(1) of the Act, and furnishing of the details by the assessee, in response to that notice, and then after examination of the issue by AO and then to take a plausible view, by assessing officer is not sufficient, as we have noted that Hon'ble Apex Court in the case of Malavar Industries Ltd. (supra) has clearly pointed out that the view taken by the assessing officer, should be sustainable in the eyes of law. Therefore, in these circumstances, we have to examine whether it was necessary for the assessing officer to accept the ratio laid down by the Hon'ble Jurisdictional High C....
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.... Jurisdictional Gujarat High Court in the case of Sabarkantha District Co-operative Milk Producers Union Ltd. In Tax Appeal No. 473 of 2014 dated 16-06-2014 (Guj HC) held that interest received from the co-operative bank is allowable as a deduction u/s. 80P(2)(d) of the Act. We also find that there is another judgment of the Hon'ble Gujarat High Court in the case of Surat Vankar Sahakari Sangh Ltd. 421 ITR 134 (Guj HC) wherein the Hon'ble Gujarat High Court held that interest received from co-operative bank is allowable deduction u/s. 80P(2)(d) of the Act. Therefore, we find that the above judgments i.e. in case of Sabarkantha District Co-operative Milk Producers Union Ltd (supra) and in case of Surat Vankar Sahakari Sangh Ltd. (supra), the Hon'ble Jurisdictional High Court clearly held that interest received from Cooperative banks, are allowable as a deduction u/s. 80P(2)(d) of the Act. These two old judgments were not distinguished by the Hon'ble Jurisdictional High court in the case of Katlary Karayana(supra) i.e. the Hon'ble Jurisdictional High Court of Gujarat did not overrule and did not distinguish and reject the earlier judgments delivered by it in case of Sabarkantha ....
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....akari Sangh Ltd. (supra) and the ratio of these old judgments namely; (i) Sabarkantha District Cooperative Milk Producers Union Ltd (supra) and, (ii) Surat Vankar Sahakari Sangh Ltd. (supra) would still be applicable to the assessee under consideration, as these judgements never distinguished and never overruled by constituting a larger Bench by the Hon'ble Jurisdictional Gujarat High Court. Hence, we find that the assessing officer has definitely taken a plausible view after examination of the issue under consideration which cannot be subject to revision by the ld. PCIT u/s. 263 of the Act because the view taken by the assessing officer is sustainable in law. Therefore, the argument advanced by the ld. D.R. for the Revenue, to the effect that assessing officer has failed to make compliance of the judgment of Hon'ble Jurisdictional High Court of Gujarat in the case of Katlary Karayana(supra), is not acceptable, as the assessing officer, has taken the view which is sustainable in the eye of law, based on the old judgements of the jurisdictional High Court of Gujarat, which are direct judgements on the issue under consideration, hence, there is no violation of judicial discipline by ....
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....of Katlary Karayana (supra) does not apply to the assessee under consideration and therefore the view taken by the assessing officer is plausible view and sustainable in law. Therefore, in fact, the assessing officer has followed the judicial discipline as mentioned in the judgement of Thane Electricity Supply Ltd. (supra), therefore, the plea raised by the ld. D.R. for the Revenue is hereby rejected. (iii) The third argument advanced by Ld. CIT-DR for the Revenue is that assessing officer, no doubt, issued the notice u/s. 142(1) of the Act to conduct inquiry and assessee has submitted the reply in response to that notice, however, the assessing officer has not applied his mind that deduction u/s 80P(2)(d) of the Act is not available in respect of interest received from co-operative bank. In this context, we state that assessing officer after taking the details and evidences from the assessee, has examined thoroughly and taken a plausible view that deduction u/s. 80P(2)(d) of the Act is available to the assessee under consideration in view of the old decisions of the Hon'ble Gujarat High Court in the case of Sabarkantha District Co-operative Milk Producers Union Ltd (supra....
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....t considered the ratio of the Hon'ble jurisdictional High Court in the case of Katlery Karyana (supra), in the following recent judgments of ITAT, Rajkot, which are reproduced below: (i) Kutch District Co-operative Milk Producers Union Ltd., 159 taxmann.com 347, order dated 29.01.2024 (ii) Rajkot Jilla Sahakari Kharid Vechan Sangh Limited, in ITA No. 49/Rjt/2022, order dated 09.208.2023 (iii) Shree Keshav Co-operative Credit Society Ltd., in ITA No. 26/Rjt/2022, order dated 31.05.2022 The ld DR pointed out that in accordance with the decision of Hon'ble Supreme Court in the case of ACIT, Rajkot Vs. Saurashtra Kutch Stock Exchange Ltd, dated 15/09/2008, (2008) 173 Taxman 322 (SC), wherein amongst others, it was held that non-adherence to orders of Jurisdictional High Court and Supreme Court is a mistake apparent on record, therefore, the above orders of the jurisdictional Tribunal require rectification under section 254 (2) of the Act. In this regard, we find that the Co-ordinate Bench of Rajkot, in the above decisions, has clearly considered the old judgments rendered by the Hon'ble Jurisdictional, Gujarat High Court, namely, (i) Surat Vandar....
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....dgment of the Hon'ble Jurisdictional Gujarat High Court in the case of Sabarkantha District Co-operative Milk Producers Union Ltd (supra) and in the case of Surat Vankar Sahakari Sangh Ltd, (supra) has taken a plausible view, which is sustainable in the eye, law. The assessing officer has not considered the judgement of Hon'ble Gujarat High Court in the Katlary Karayana (supra), as the ratio laid down by the Hon'ble Gujarat High Court in the case of Katlary Karayana(supra)is not applicable to the assessee, under consideration and hence there is no violation of the principles laid down by the Hon'ble Supreme Court in the case of Saurastra Kutch Stock Exchange Ltd. (supra). We are of the view that the judgement of the Hon'ble Jurisdictional High Court of Gujarat in the case of Katlary Karayana(supra), is not binding on the assessing officer, as we have stated that this judgement is in different context of section 194A of the Act and specially it is in the context of income escaped assessment u/s 147 of the Act, therefore, the ratio of the judgement does not apply to the assessee, under consideration. So far as the judicial discipline is concerned, there is no violation of the judicia....
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....¥¨à¥®à¥® 20.dll.22-2-2010 Sr. Name and Quality Purchase Nojof the shares held Price per Total Purchase Date of Consideration | Purchase Funds for Source of Date of Sale Consi- deration Calculation of Capital Gains/ Loss on Sale Unit Investment Sale > The details in respect of Investments in Shares is enclosed herewith for your verification in Annexure C. 3. The Details in respect of deduction claimed under chapter VI-A is as under: i. The Details of the earnings for which deductions claimed under section 80P(2)(a)(i) & 80P(2)(d) is as under: Shri Avadh Nagrik Sarafi Sahkari Mandali Limited Calculation of Amount of Deduction under various sub sections of section 80P of the Act No. Particulars Amt. Amt Amt. A Section 80P(2)(a)(i) - Income received on Loan which has been given to members of the Co-operative Society "Shri Avadh Nagrik Sarafi Sahkari Mandali Limited" 24,42,937.00 Net Profit during the A.Y.2018-19 32,76,731.00 Add: Disallowance as per P&L Account 10,59,992.00 Vehicle Depreciation Fund Exp. Member's Gift Exp. Depreciation 4,11,045.00 2,25,020.00 4,23,927.00 Less: Income from Other Head (-)18,....