2026 (8) TMI 611

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....07.2025, passed under Section 250 of the Income-tax Act, 1961 ('the Act' in short) for Assessment Years 2010-11 & 2015-16. 2. Since the issues involved in these appeals are identical, they were heard together and are being disposed of by this common order for the sake of convenience. For adjudication, we take ITA No. 803/SRT/2025 for Assessment Year 2010-11 as the lead case. 2.1 The assessee has raised the following grounds of appeal::- "1. On the facts and in the circumstances of the case as well in law, the CIT (Appeals) Addl./JCIT (A)-10 Mumbai erred in upholding the order passed by DCIT, CPC, Bengaluru (for the sake of brevity "The AO") u/s 143(1) of the Act for the income assessed at Rs. 1,59,90,311/- against the returne....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ute that the Surat District Co-operative Bank Ltd. is a co-operative society duly registered under Gujarat Co-operative Societies Act, 1961. The ld. AR has relied on the decisions of the Hon'ble jurisdictional High Court in case of Ashwinkumar Arban Co-operative Society Ltd. (supra) and Kutch District Cooperative Milk Producers Union Ltd. (supra), wherein the Hon'ble jurisdictional High Court held that deduction u/s 80P(2)(d) is available to cooperative societies on income earned as interest on investment made with co-operative bank, which in turn is a co-operative society. In case of Ashwanikumar Arban Co-op. Society Ltd. (supra), it was held as under: "28. Having heard learned advocates for the respective parties and considering ....