SRI GANGANAGAR ZILA DUGDH UTPADAK SAHAKARI SANGH LIMITED,HANUMANGARH vs. ITO WARD-1, HANUMANGARH

ITA 788/JODH/2025Status: HeardITAT Jodhpur10 August 2026AY 2022-2312 pages
AI SummaryPartly Allowed

What were the facts?

The assessee, a cooperative society, claimed deductions under Section 80P for interest earned on income-tax refunds and bank deposits. The Assessing Officer and CIT(A) disallowed these claims, treating them as income from other sources or not fulfilling the conditions of Section 80P.

What did the Tribunal hold?

The Tribunal held that interest on income-tax refunds is not eligible for deduction under Section 80P(2)(b) as it does not arise from the primary business activity. Similarly, interest from commercial banks is not eligible under Section 80P(2)(d) as the investment is not with another cooperative society.

What were the issues?

Whether interest on income-tax refunds and interest from commercial bank deposits are eligible for deduction under Section 80P for a cooperative society. Whether excess contribution to an approved gratuity fund is allowable.

Which sections of the Income-tax Act were involved?

Section 80P,Section 36(1)(v),Section 270A

AI-generated summary — verify with the full judgment below

IN THE INCOME TAX APPELLATE TRIBUNAL JODHPUR BENCH, JODHPUR BEFORE SHRI AMIT SHUKLA, HON’BLE JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, HON’BLE ACCOUNTANT MEMBER ITA Nos. 786, 787 & 788/Jodh/2025 (Assessment Years – 2018-19, 2020-21 & 2022-23)

Sri Ganganagar Zila Dugdh ITO, Ward 1, Utpadak Sahakari Sangh L Hanumangarh Gangmul, Gangmul Dairy, Industrial Area,, Hanuman Garh Junction, Rajasthan-335512 PAN No. JDHSO 4215 B Assessee by None Revenue by Prerna Choudhary, Addl. CIT-DR (Physical) Date of Hearing 10 / 08 / 2026. Date of Pronouncement 10 / 08 / 2026

PER BENCH: The aforesaid appeals have been filed by the assessee, Sri Ganganagar Zila Dugdh Utpadak Sahakari Sangh Ltd., against the respective orders passed by the Ld. CIT(A) for the assessment years under consideration. Since the issues arising in these appeals are either common or interlinked and emanate from substantially similar facts, they were heard together and are being disposed of by this consolidated order. Asst. Years: 2018-19, 2020-21, 2022-23

2.

The assessee is a co-operative society registered under the Rajasthan State Co-operative Societies Act and is engaged in the activity of collection, preservation, processing

The order continues below.

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