Jaisingpur Vyapari Nagri Vs ITO (ITAT Pune)
The Pune Bench of the Income Tax Appellate Tribunal considered an appeal filed by Jaisingpur Vyapari Nagri, a primary credit co-operative society registered under the Maharashtra State Co-operative Societies Act, against the CIT(A)/NFAC order dated 19.09.2025 for A.Y. 2015-16. The assessee was engaged in providing credit facilities to members and accepting deposits from them and had not furnished a return of income under Section 139.
The assessment was reopened under Section 147 after information showed that the assessee had deposited cash exceeding Rs.10 lakh in other cooperative banks and purchased time deposits exceeding Rs.2 lakh. A notice under Section 148 dated 30.03.2022 was issued after following the procedure under Section 148A and obtaining approval from the PCCIT, Pune. The Assessing Officer subsequently sought information from banks under Section 133(6) and initially proposed an addition of Rs.22,82,84,247.
The case was later transferred from faceless assessment under Section 144B(8) to the Jurisdictional Assessing Officer because the PAN was not registered on the e-filing portal. The assessee submitted information and documents on 15.03.2023. On examining the submissions and the Profit & Loss Account, the Assessing Officer found bank interest income of Rs.71,70,196 which, according to the assessment order, had not been offered under “Income from other sources”. Relying on the Supreme Court judgment in the Totgars Sale Society Ltd. case, the Assessing Officer denied deduction under Section 80P and assessed total income at Rs.71,70,196 under “Income from other sources”.
