SHRI. KALIKAMBA VIVIDHODDESHA SAHAKARI SANGHA LIMITED,UDUPI vs. INCOME TAX OFFICER, WARD-1 & TPS, UDUPI

ITA 119/BANG/2025Status: DisposedITAT Bangalore16 September 2026AY 2017-1813 pages
AI SummaryAllowed

What were the facts?

The assessee, a co-operative credit society, claimed deduction under Section 80P(2)(a)(i) for its business profits. The Assessing Officer denied this deduction, citing the Supreme Court's decision in Citizen Co-operative Society Ltd. and alleging violation of the Karnataka Co-Operative Societies Act due to excess nominal members and transactions with them.

What did the Tribunal hold?

The Tribunal held that nominal members are considered members under the Karnataka Co-Operative Societies Act, 1959. Therefore, transactions with nominal members do not disqualify the assessee from claiming deduction under Section 80P(2)(a)(i).

What were the issues?

Whether transactions with nominal members, who are defined as members under the state co-operative societies act, disqualify a co-operative society from claiming deduction under Section 80P(2)(a)(i) of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 80P(2)(a)(i),Section 143(3),Section 2(f)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SANDEEP SINGH KARHAIL

PER SANDEEP SINGH KARHAIL, JUDICIAL MEMBER:

The assessee has filed the present appeal against the impugned order dated 20/12/2024, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, [“learned CIT(A)”], for the assessment year 2017-18. ITA 119/BANG/2025 SHRI. KALIKAMBA VIVIDHODDESH

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 80P(2)(a)(i)

All 2,331 judgments and leading authorities on Section 80P(2)(a)(i) →

Recent GST High Court judgments

Search GST case law →