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IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI

BEFORE SHRI OM PRAKASH KANT, AM

AND

MS. KAVITHA RAJAGOPAL, JM

ITA Nos.6895, 6896, 6897, 6898, 6899 & 6900 /Mum/2025

(Assessment Years: 2014, 2015, 2016, 2017, 2020 & 2022)

M/s. Brihanmumbai Police Income Tax Officer,

Karmachari Sahakari Patsanstha Ward 20(1)(1),

Maryadit, PC-124, Aayakar Bhavan,

Apna Bazaar Co-operative, 106A, Vs. Maharshi Karve Road,

Govindji Keni Road, New Marine Lines,

Naigaon, Dadar (E), Churchgate

Mumbai – 400 014 Mumbai – 400 020

PAN: AACFB5378G

(Appellant) : (Respondent

Assessee by : Shri P.S. Shingte, C.A.

Respondent by : Shri Leyaqat Ali Aafaqui, Sr. AR

Date of Hearing : 18.12.2025

Date of Pronouncement : 24.12.2025

O R D E R

Per Bench:

The captioned appeals are filed by the assessee, challenging the orders of the

Learned Commissioner of Income Tax (Appeals) [‘Ld. CIT(A)’ for short], National

Faceless Appeal Centre (‘NFAC’ for short) passed u/s. 250 of the Income Tax Act, 1961

(‘the Act'), pertaining to the Assessment Years (‘A.Y.’ for short) 2014, 2015, 2016,

2017, 2020 & 2022. As the facts are identical, we hereby pass a consolidated order by

taking ITA No.6895/M/2025 as a lead case.

ITA Nos.6895/Mum/2025 & ors.

M/s. Brihanmumbai Police Karmachari Sahakari Patsanstha Maryadit

2. The assessee has raised the following grounds of appeal:

“1. On the facts and in the circumstances of the case and in law learned AO erred in

rejecting partial deduction under section 80P(2)(a)(i) for a sum of Rs.1,36,01,527/- of

appellant society without appreciating the fact that earning of interest is an integral part

of society’s business and appellant prays for allowing such deduction.

2. On the facts and in the circumstances of the case and in law the learned Assessing

Officer erred in treating a sum of Rs.1,36,01,527/- being interest received on investment

with banks as ineligible amount for calming deduction under section 80P (2)(a)(i) without

appreciating the fact that earning of interest is an integral part of societies business and

appeal and prays for allowing such deduction.

3. On the facts and in the circumstances of the case and in law the learned Assessing

Officer erred in treating the interest received from investment as income from other

sources by rejecting appellant’s contention that said interest income is integral part of

business activity and your appellant prays for cancellation of Assessing officer’s action.

4. Without prejudice to above ground on the facts and circumstances of the case and in

the law Learned Assessing Officer erred in not allowing the deduction under section

80P(2)(d) on interest income received from other co-operative society. Your appellants

pray for allowing of the same.

5. Without prejudice to above ground, On the facts and circumstances of the case and in

the law Learned Assessing Officer erred in treating entire interest income as interest

income received from other co-operative society or bank without allowing deduction on

account of interest expenses.

Your appellant prays for such deduction Your appellant prays for deletion of entire

addition. Your appellant craves for to add, alter amend, modify, delete any or all grounds

of appeal before or during the course of hearing in the interest of principle of natural

justice.”

3. The brief facts of the case are that the assessee is a cooperative society engaged in

the activities of providing credit facility to its members and had filed its return of income

for the year under consideration dated 14.11.2014 declaring total income at Rs.11,38,500/-

after claiming deduction of Rs.1,36,01,527/- u/s. 80P(2)(d) of the Act and the same was

processed u/s. 143(1) of the Act. The assessee’s case was selected for scrutiny and

assessment order u/s. 143(3) of the Act was passed determining total income at

2

ITA Nos.6895/Mum/2025 & ors.

M/s. Brihanmumbai Police Karmachari Sahakari Patsanstha Maryadit

Rs.11,88,500/- vide assessment order dated 15.11.2016. Subsequently, the assessee’s case

was reopened vide notice u/s.