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Documents citing M/S Tumkur Merchants Souharda Credit ... vs Assessee on 19 February, 2014

Sri Vishnu Vilas Souharda Pattina ... vs Income Tax Officer, Ward-1 & Tps, , ... on 31 December, 2025

As argued by the Ld.AR, the Hon'ble Jurisdictional High Court in the case of Tumkur Merchants Souharda Credit Co-operative Ltd. vs. ITO reported in (2015) 55 taxmann.com 447 (Karnataka) had also considered the Hon'ble Supreme Court judgment relied on by the Ld.PCIT and differentiated the said judgment and held that the law laid down by the Hon'ble Supreme Court would not be applicable to the facts of the present case. Therefore, the reliance made by the Ld.PCIT on the Hon'ble Supreme Court judgment to revise the order of the AO is not correct. We have also considered the facts involved in the present case and also the details furnished by the assessee to the show cause notice issued u/s. 263, which was extracted in the earlier paragraphs, the assessee had an obligation to make short term deposits under the provisions of the Karnataka Souharda Sahakari Act, 1997. If the assessee had not followed the said mandate, then the authority could take action on the society and even the registration could have been cancelled by the authority. In such circumstances only, the assessee had deposited the said amounts and earned the interest income out of the said deposits. By considering the Division Bench judgment of the Hon'ble Jurisdictional High Court in the case of Tumkur Merchants Souharda Credit Co-operative Ltd.
Income Tax Appellate Tribunal - Bangalore Cites 16 - Cited by 0 - Full Document

Sir. M. Vishweshwaraiah Co-Op. Society ... vs Income-Tax Officer, Ward-1, , Shimoga on 11 May, 2018

At this juncture, the bench wanted to know regarding the facts of the present case because the decision of Hon'ble Karnataka High Court rendered in both these cases i.e. PCIT and Another Vs. Totagars Co-operative Sale Society (supra) and Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (supra) are on the same line but the conclusion is different because the facts are different.
Income Tax Appellate Tribunal - Bangalore Cites 1 - Cited by 0 - Full Document

M/S Sangam Credit Co-Operative Society ... vs Income Tax Officer Ward-3(2)(1), ... on 1 June, 2018

At this juncture, the bench wanted to know regarding the facts of the present case because the decision of Hon'ble Karnataka High Court rendered in both these cases i.e. PCIT and Another Vs. Totagars Co-operative Sale Society (supra) and Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (supra) are on the same line but the conclusion is different because the facts are different.
Income Tax Appellate Tribunal - Bangalore Cites 3 - Cited by 0 - Full Document

Bijapur Co-Op Credit Society Ltd, ... vs Income-Tax Officer, Vijayapur on 31 December, 2018

ITA Nos. 1306 & 1314/Bang/2016 & 1134/Bang/2017 Page 6 of 6 (supra) then the issue should be decided against the assessee and if the facts of the present case are in line with the facts in the case of Tumkur Merchants Souharda Credit Cooperative Ltd. vs. ITO (supra) then the issue should be decided in favour of the assessee. Needless to say, reasonable opportunity should be provided to assessee.
Income Tax Appellate Tribunal - Bangalore Cites 8 - Cited by 0 - Full Document

M/S. Moorthedara Seva Sahakari Sangha ... vs The Income Tax Officer, Ward- 1, Puttur on 7 August, 2019

At this juncture, the bench wanted to know regarding the facts of the present case because the decision of Hon'ble Karnataka High Court rendered in both these cases i.e. PCIT and Another Vs. Totagars Co-operative Sale Society (supra) and Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (supra) are on the same line but the conclusion is different because the facts are different.
Income Tax Appellate Tribunal - Bangalore Cites 1 - Cited by 0 - Full Document

M/S Sri Ramaseva Bahusara Kshatriya ... vs Income Tax Officer Ward-1 , Shimoga on 11 May, 2018

At this juncture, the bench wanted to know regarding the facts of the present case because the decision of Hon'ble Karnataka High Court rendered in both these cases i.e. PCIT and Another Vs. Totagars Co-operative Sale Society (supra) and Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (supra) are on the same line but the conclusion is different because the facts are different.
Income Tax Appellate Tribunal - Bangalore Cites 2 - Cited by 0 - Full Document

M/S Kappalaguddi Vyavasaya Seva ... vs Income Tax Officer Ward-4 , Belgavi on 20 March, 2018

At this juncture, bench wanted to know regarding the facts of the present case because the decision of Hon'ble Karnataka High Court rendered in both cases i.e. PCIT and Another Vs. Totagars Co-operative Sale Society(supra) and Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO(supra) are on the same line but the conclusion is different because the facts are different.
Income Tax Appellate Tribunal - Bangalore Cites 1 - Cited by 0 - Full Document

M/S Sri Arya Vysya Sri Rama Sahakara ... vs The Income Tax Officer Ward-1 , ... on 13 July, 2018

In reply, it was submitted by ld. AR of assessee that the facts of present case are in line with the facts in the case of Tumkur Merchants Souharda Credit Cooperative ITA No.1955/Bang/2018 Page 4 of 4 Ltd. Vs. ITO (supra) but there is no finding of any of the authorities below on this factual aspect and therefore, the matter may be restored back to the file of AO for fresh decision by examining the facts of present case in light of both these judgments of Hon'ble Karnataka High Court rendered in the case of Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (supra) and Totgars Co-operative Sales Society Ltd. (supra). The ld. DR of revenue supported the orders of authorities below.
Income Tax Appellate Tribunal - Bangalore Cites 3 - Cited by 0 - Full Document

M/S Bank Officers And Officials House ... vs Assistant Commissioner Of Income Tax ... on 1 June, 2018

At this juncture,the bench wanted to know regarding the facts of the present case because the decision of Hon'ble Karnataka High Court rendered in both these ITA No. 1202/Bang/2018 Page 3 of 4 cases i.e. PCIT and Another Vs. Totagars Co-operative Sale Society (supra) and Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (supra) are on the same line but the conclusion is different because the facts are different.
Income Tax Appellate Tribunal - Bangalore Cites 3 - Cited by 0 - Full Document

Bijapur District Police Co-Operative ... vs Income Tax Officer, Ward-1, Vijayapur on 23 March, 2018

At this juncture, bench wanted to know regarding the facts of the present case because the decision of Hon'ble Karnataka High Court rendered in both these cases i.e. PCIT and Another Vs. Totagars Co-operative Sale Society(supra) and Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO(supra) are on the same line but the conclusion is different because the facts are different.
Income Tax Appellate Tribunal - Bangalore Cites 2 - Cited by 0 - Full Document
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