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2025 (2) TMI 1961

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....e common issues are involved in these appeals, these appeals were heard together and are being disposed of by this single consolidated order for the sake of convenience and brevity. 2. Facts of the case, in brief, are that the assessee is a cooperative society registered under Maharashtra Co-operative Society Act, 1960 and engaged in the business of providing credit facilities to it's members. The assessee society has granted loan to members and derived interest therefrom and thus has earned income by providing credit facilities to it's members. The assessee society has accepted deposit and granted loan only to it's members, the requisition condition for grant of deduction and eligible for deduction u/sec.80P of the Act. 3. The case o....

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....erefore, submitted that the matter in issue may please be remit back to the file jurisdictional Assessing Officer for verification in the interest of justice. 6. The Learned DR on the other hand relied on the orders of the authorities below. He submitted that since the assessee did not file it's return of income and nor furnished any reply to the statutory notices and in absence of any documentary evidence to substantiate it's claim, the Assessing Officer rightly made the impugned additions in the hands of the assessee for the assessment years 2013-14, 2014-15 and 2016-17 and since the same position continued even during appellate proceedings, the learned CIT(A) confirmed the additions made in the hands of the assessee for the above asse....

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....AG./ 2024 are allowed. 9. Now coming to the assessee's appeal ITA.No. 531/NAG/2024 for the assessment year 2020-2021. For this impugned assessment year 2020-2021 the assessee had filed it's return of income declaring income at Rs. NIL by claiming deduction u/sec.80P of the Act at Rs. 29,45,904/-. The case of the assessee selected for scrutiny under CASS. The Assessing Officer issued various statutory notices u/sec.143(2), 142(1) and show cause notice dated 23.02.2022 also calling the assessee to furnish it's explanation, documents etc., In absence of documentary evidence in support of deduction claimed u/sec.80P of the Act with respect to the incomes earned and expenses incurred towards it's activities, the Assessing Officer made additio....

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....0-21 and 2022-23 which are placed on record. He also relied on the decision of Coordinate Bench of Nagpur Tribunal which is placed on record in the case of Bhagyashri Nagri Sahakari Pat Sanstha Maryadit in ITA.No. 374/NAG/2023 vide order dated 18.09.2024, the assessee was granted relief. He, accordingly, submitted that the assessee is entitled to get relief u/sec.80P of the Act and prayed that the grounds of assessee be allowed in the interest of justice. 13. The Learned DR, on the other hand, strongly relied on the orders of the authorities below. He submitted that since the assessee failed to justify it's business activities and failed to establish that the activities carried-out by it, the learned CIT(A) has rightly confirmed the orde....