JALGAON JILHA PRATHAMIK SHIKSHAK SAHAKARI PATPEDHI LIMITED,JALGAON vs. ITO, WARD 1(4), JALGAON, JALGAON

ITA 2874/PUN/2026Status: DisposedITAT Pune10 September 20267 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that interest earned by a co-operative credit society from funds deposited with banks is eligible for deduction under Section 80P(2)(a). This decision followed various High Court judgments that distinguished the Totgars case and affirmed the eligibility of such interest income.

What were the facts?

The assessee, a co-operative society providing credit facilities, claimed deduction under Section 80P(2)(a) for interest income earned from deposits with banks. The Assessing Officer disallowed this deduction, relying on the Totgars case.

What were the issues?

Whether interest income earned by a co-operative society from its bank deposits is eligible for deduction under Section 80P(2)(a) of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 80P(2)(a)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “SMC”, PUNE

Before: SHRI Dr. DIPAK P. RIPOTE & SHRI VINAY BHAMORE

For Appellant: Shri Shubham Rathi (virtually)
For Respondent: Shri Prashant Barate

PER Dr. DIPAK P. RIPOTE, A.M : This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), NFAC, Delhi [Ld.CIT(A)], passed u/s. 250 of the Income Tax Act, 1961 (‘the Act’) for AY 2020-21 on 13.05.2026, emanating from the Assessment Order u/s 143(3) r.w.s 144B of the Act, dated 27.09.2022. Findings and Analysis :

2.

We have heard both the parties and perused the records. In this case, the assessee is a Co-operative Society and is providing credit facilities to its members. The assessee has submitted its return of income for the AY 2020-21 on 28.12.2020 declaring total at income of Rs. Nil after claiming dedu

The order continues below.

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