SOUBHAGYALAXMI VIVIDHODDESHA SOUHARDA SAHAKARA SANGHA NIYAMITHA KOPPALA,KOPPAL vs. PCIT, HUBLI, HUBLI

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. PCIT, Hubli dated 26.12.2025 vide DIN & Order No. ITBA/REV/F/REV5/2025-26/1084106678(1) passed u/s 263 of the Income Tax Act, 1961 (in short “the Act”) for the assessment year 2022-23.

“That the impugned passed by the learned PCIT under Section 263 ofthe Act dated 26.12.202$ is bad in law. void ab-injtio„ and contrary to the facts and circumstances ofthe case and deserves to be quashed.

That the learned PCIT erred in law and on facts in assuming jurisdiction under Section 263 of the Act by holding that the assessment order passed by the AO

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 2 of 30 under Section 143(3) dated 18.03.2024 was erroneous in so far as it was prejudicial to the interest ofthe revenue. It is submitted that the twin conditions required for invoking jurisdiction under Section 263, i.e., the order being (i) erroneous and prejudicial to the interest of the revenue, must co-exist. in the Appellant's case, neither of these conditions is satisfied.

The original assessment was framed aner a detailed scrutiny where all the relevant details were called for and examined by the ACL The AO, aner due application of mind, accepted the claim of deduction under Section SOP. Therefore, the order cannot be termed as 'erroneous'.

That the learned PCIT erred in holding the assessment order to be erroneous on the grounds that the AO failed to make proper inquiries or verification, It is submitted that the case was selected for scrutiny for reasons including 'High interest expenditure' and ‘High liabilities'. This indicates that the financial aspects, including income and expenditure, were subject tn examination by the AO- The AO took a plausible view Of the matter, and the learned PCIT cannot invoke Section 263 merely to substitute his own view for that of the AO, The lack of an explicit discussion in the assessment order on a particular point does not, by itself, mean that the AO did not apply his mind to the issuer The AO is not required to write an elaborate-thesis on every issue, That the learned PCIT erred in law and on facts in directing that the interest income of Rs.50,45,102/- earned from investments with other co-operative society, banks is not eligible for deduction under Section 80P(2)(d) ofthe Act.

It is submitted that Section of the Act allows for a deduction in respect of any income by way of interest or dividends derived by a co-operative society from its investments with any other Co-operative society. Co-operative banks are fundamentally cooperative societies registered under the relevant Co- operative Societies Act and engaged in the business of banking, The funds invested by the Appellant were not surplus funds parked for earning interest, but were business funds, including those maintained to comply with statutory liquidity requirements, which is an activity ancillary and incidental to its main business of providing credit facilities to its members. interest earned from such investments is attributable to the business of the society and is eligible for deduction (1). That the learned PCIT erred in relying on the judgment of the Hon'ble Supreme Court in the ease of Totgars Co-operative Sale Society Ltd. Vs. Income-tax Officer, 322 ITR 283(SC) and the judgment of the Hon'ble

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 3 of 30 Karnataka High court in ITA No. 100066/2016, as the facts of the said cases are distinguishable from the Appellant's ease,

ln. the case of Totgars, the Hon'ble Supreme Court was dealing with a society engaged in marketing agricultural produce, and the funds invested were surplus funds not immediately required for business, In the Appellant's eases the Appellant is a credit co—operative society, und the investments are intrinsically linked to its business operations.

The issue of whether interest from co—operative banks is eligible for deduction under Section has been a subject of divergent views. Where two Views are possible and the AO has adopted one of them, the order cannot be termed as erroneous and prejudicial to the interest of the revenue for the purpose of invoking Section 263,

The principle Of Surplus/Idle Funds The Hon'ble Supreme in the case of Totgars Co-operative Sale Society Ltd, Income Tax Officer, 322 ITR 283(SC), held that interest earned on the investment of surplus or idle funds that are not immediately required for the business or the society is not attributable io its core business operations.

Such interest income, according to the Supreme Court, should be classified under the head "Income from Other Sources" under Section 56 of the Act, and not as business income. Consequently, it is not eligible for deduction under Section 80P(2)(a)(i).

That the learned PCIT has failed to appreciate that the interest income earned from other co-operative societies is part of the profits and gains of business for a co-operative society engaged in providing Credit facilities to its members and is thus eligible for deduction under Section 80P(2)(a)(i) of the Act.

Deduction under Section 80P(2)(a)(i):

clause allows for a deduction of the whole of the profits and gains of business Attributable certain activities, including “carrying on the business of banking f or providing credit facilities to its members”.

Interest received by a co-operative society on deposits made from its circulating capital is considered part of its business profits and is therefore deductible

Interest earned on bank deposits can be considered ancillary -and incidental to the business of providing credit facilities to its members and hence may be

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 4 of 30 eligible for exemption (1). This applies when the funds are not surplus but are required for the operational needs of the society, such as maintaining statutory liquidity,

interest received by a co-operative society on deposits made from its Circulating capital is deductible as being part of the profits or its business [1]). The investments made by the Appellant were its circulating capital and were incidental to its primary business activity.

That the order passed by the learned PCIT is based on a change of opinion and is a mere substitution of his view over the plausible viewtaken by the AO, which is not permissible under the scope of Section 263 of the Act,

The Appellant craves leave to add, alter, amend, or withdraw any ofthe grounds of appeal at w before the time ofthe bearing.

Karnataka HC — Tumkur Merchants Credit Co-op Society: Deduction Allowed — Deposits incidental to credit activity,

Punjab Haryana HC: Deduction Allowed — Statutory deposits in nationalized banks

PRAYER It is, therefore, most humbly prayed that the Hon’ble Tribunal may be pleased to:

a) Quash the impugned order dated 26.12.2023 passed by the learned PCIT under Section 263 of the income Tax Act, 1961.

b) Resotre the original assessment order dated 18.03.2024 passed by the learned AO under Section 1430) of the Act.

c) Grant any other relief as the Hon’ble members may deem lit and proper in the facts and circumstances of the case,

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 5 of 30 the case of the assessee society was selected for scrutiny under CASS to examine the following issues:-

i) Low income in comparison to high loans/advances/investments in shares appearing in the balance sheet. ii) High interest expenditure and huge advances in excess of total proprietors/partners fund. iii) High liabilities as compared to low income/receipts.

3.1 Accordingly, the notice u/s 143(2) of the Act as well as notice u/s 142(1) of the Act along with the detailed annexure having questionnaire was issued to the assessee. In response to statutory notices issued u/s 143(2) as well as 142(1) of the Act, the assessee submitted detailed reply on various dates along with the copies of audited balance sheet, profit & loss account, copies of bank statements, bye laws of society, registration copy, loan documents and interest paid ledgers on secured loans, details of other payables, details of loans and advances given during the year, details of investments in shares, details of interest paid during the year and expenses ledger. Further, during the course of assessment proceedings, the assessee also submitted computation of income, details of other income declared in profit & loss account, nature of activity, list of members, interest receipt certificate along with the ledger of members to whom interest given of FD and to whom loan given during the year. After considering replies of the assessee along with the details and documentary evidences, the AO accepted the reply of the assessee and taken no adverse view for variation in taxable income of the assessee and accordingly accepted the returned income of the assessee. Thus, the AO after proper examination of the details along with the documentary evidence/written submission/explanation etc. submitted by the

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 6 of 30 assessee, completed the assessment proceedings u/s. 143(3) r.w.s 144B of the Act by holding that no adverse inference is required to be drawn as the issues were explained by the assessee and the submission is found in order regarding the issue for which case had been selected for assessment proceedings and accordingly accepted the returned income as such for the assessment year under consideration.

3.2 The ld. Principal Commissioner upon calling for the assessment records and on examination of the same, observed that the order passed u/s. 143(3) r.w.s. 144B of the Act on 18.03.2024 was erroneous in so far as it is prejudicial to the interest of revenue on the issue of interest income earned from various banks and co- operative banks allowed as deduction u/s 80P of the Act. The ld. Principal Commissioner noticed that the assessee society had earned interest income from Co-operative Banks/ Commercial Banks amounting to Rs.50,45,102/- which according to him did not constitute business income and therefore the same needed to be taxed under the head “Income from other Sources” u/s 56 of the Act. Hence, the said amount would be ineligible for deduction u/s 80P(2)(a)(i) of the Act, which the AO had failed to examine and considered the same in the total income under the head income from other sources in view of the decision of the Hon’ble Supreme Court in the case of Totagars Co-operative Sale Society Limited vs. Income Tax Officer reported in 322 ITR 283 (SC) which held that utilization of surplus fund/ investments are taxable under the head “income from other sources” and therefore not eligible for deduction under section 80P(2)(a)(i) of the Act.

3.3 Further, the ld. Principal Commissioner also of the opinion that since the income earned was interest on FDs/ Reserve fund/Liquidity assets with co-operative Banks/Commercial banks,

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 7 of 30 rather than interest/ dividend income from other co-operative societies, therefore the said income would also be not eligible for deduction under section 80P(2)(d) of the Act in view of the decision of the Hon’ble Supreme Court in the case of Totagars Co-operative Sale Society Limited vs. ITO(2010) 188 taxman 282 which affirmed that interest earned on deposits with banks would fall under the head “income from other sources” u/s. 56 of the Act and not under section 28 of the Act. Further, in this regard the ld. PCIT also relied upon the decision of Hon’ble High Court of Karnataka in the case of Principal Commissioner of Income Tax vs. Totagars Co-operative Sale Society Ltd. in ITA No.100066/2016 dated 16/06/2017 which held that the income by way of interest earned by deposit or investment of idle or surplus funds does not change its character irrespective of the fact whether such income of interest is earned from a scheduled bank or co-operative bank. Considering the above, as the interest income earned from FD/ Reserve fund/ Liquidity assets with Co-operative banks/Commercial banks needs to be brought to tax under the head “income from other sources”, the ld. PCIT found the assessment order passed to be erroneous in so far as it is prejudicial to the interest of revenue and accordingly the proceeding under 263 of the Act was initiated by issuing notice dated 16.09.2025 to file its objections, if any.

3.4 In response to the said notice, the assessee submitted its reply through e-filing portal on 13.11.2025 by quoting certain case laws claimed to be in favour of the assessee. Further, the assessee in its reply stated that various ITAT in their judgment allowed the said deduction on account of interest earned from co-operative banks.

3.5 The ld. PCIT after perusal of the submission of the assessee did not accept the reply of the assessee in view of the decision of

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 8 of 30 Hon’ble Supreme Court in the case of Totagars Co-operative Sale Society Limited vs. ITO (2010) 188 Taxman 282 as well as the decision of the Hon’ble Karnataka High Court in the case of Principal Commissioner of Income Tax, Hubli vs. Totagars Co- operative Sale Society, Sirsi in ITA No. 100016/2016 dated 16/06/2017 and thus held that the AO has failed to make proper enquiry regarding nature of business income declared by the assessee society, which included interest income from Co-operative Bank/Commercial bank and did not comply with the ratio laid down by the Hon’ble Supreme Court &the Jurisdictional High Court(Supra). Thus, Clause (a) and clause (d) of the explanation-2 of section 263 are attracted in the instant case.

3.6 In view of the above, the ld. PCIT was of considered opinion that the assessment order passed u/s. 143(3) r.w.s 144B of the Act on 18.03.2024 was erroneous in so far as it is prejudicial to the interest of revenue as the issue in respect of taxing interest income on account of investment in commercial and Co-operative banks u/s 56 of the Act needs further verification on the part of the AO and accordingly the assessment order passed u/s. 143(3) r.ws. 144B dated 18.03.2024 by the FAO was partly set-aside u/s. 263 of the Act with a direction to the AO to pass fresh assessment order by examining the facts discussed above.

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 9 of 30 of revenue to the income tax administration as a whole. Further the ld. AR of the assessee submitted that the ld. PCIT failed to appreciate that there was no error by the AO in allowing the deduction claimed u/s. 80P(2)(a)(i) of the act in view of various judgments of jurisdictional High Court which held that interest earned from co-operative bank/commercial bank are attributable to the business of assessee and should be allowed deduction u/s. 80P(2)(a)(i) of the Act. Further, the ld. A.R. of the assessee submitted that the ld. Principal Commissioner have no power to substitute the judgment as taken by the AO and held to be erroneous and prejudicial interest to the revenue especially when the AO has taken one of the plausible view. Lastly, the ld. A.R. of the assessee submitted that in the pretext of revision proceedings, the ld. PCIT cannot direct the AO to tax the interest income under income from other sources especially when AO being Quasi-judicial authority after proper examination had taken an opinion which is also in accordance with the decision of the Jurisdictional High Court which are binding upon the AO.

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 10 of 30 Totagars Co-operative Sale Society Ltd (supra) in support of his contention in order to justify the revision made by the commissioner.

7.1 The division Bench of the Hon’ble High Court of Kerala in the case of Commissioner of Income Tax v. Chandrika Educational Trust reported in (1994) 207 ITR 108 had held as under:-

“In entertaining an appeal from the Commissioner's order what the Tribunal does is to examine whether the said order is sustainable in law and whether it is within the powers conferred by section 263. Therefore, when the Commissioner has chosen to set aside the order of the Income-tax Officer only on a particular ground, the Tribunal is not entitled to go beyond and sustain the order of the Commissioner on grounds different from that relied on by the Commissioner himself.”

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7.2 The Hon’ble High Court of Kerala at Ernakulam in the case of Save a Family Plan (India) v. The Deputy Commissioner of Income Tax (Exemptions) in ITA No.81 of 2025 dated 05/11/2025 had again reiterated the same.

7.3 In view of the above, on perusal of show cause notice for hearing dated 16.09.2025 issued by the ld. PCIT for invoking the Revision Proceedings u/s 263 of the Act, we observed that the reason cited by the ld. PCIT primarily is that the assessee had received certain interest income on investment in banks/co- operative banks, which are required to be added to the income of the assessee u/s. 56 of the Act as held by the Hon’ble Supreme Court in the case of Totagars Co-operative sale Society Limited vs. Income Tax Officer (322 ITR 283) and in view of the above, the assessment proceedings u/s. 143(3) r.w.s 144B of the Act dated 18.03.2024 is found to be erroneous in so far as it is prejudicial to the interest of revenue within the meaning of section 263 of the Act, as such the AO has failed to examine and verify the above issue and failed to tax the income from other sources. Thus, we are of the considered opinion that the ld. PCIT had principally exercised his jurisdiction u/s. 263 of the Act merely because he is of the opinion that interest income on investment in commercial banks/co- operative banks were required to be added to income of the assessee u/s. 56 of the Act in view of the Apex court decision cited supra. Further, we also take note of the fact that in the above said notice for hearing dated 16.09.2025, the ld. PCIT failed to even mention under which clause(s) of the explanation- 2 of section 263 of the Act, the Assessment order shall be deemed to be erroneous in so far as it is prejudicial to the interest of Revenue. Thus, this is not the case of the revenue that no enquiry has been conducted by the AO but in fact the ld. PCIT is of the opinion that interest income on

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 12 of 30 investment in commercial banks/co-operative banks were required to be added to income of the assessee u/s. 56 of the Act & accordingly the deduction claimed by the assessee u/s 80P(2)(a)(i) of the Act is not allowed.

7.4 Now before proceedings further, it is apposite here to mention the relevant provision of Income Tax Act which is reproduced below:-

Revision of orders prejudicial to revenue.

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 13 of 30 assigned to, him under the orders or directionsissued by the Board or by the [Principal Chief Commissioner or] Chief Commissioner or [Principal Director General or] Director General or ]Principal Commissioner or] Commissioner authorized by the Board in this behalf under section 120;

[(iii)an order under section 92CA by the Transfer Pricing Officer;]

(b) ”record” [shall include and shall be deemed always to have included] all records relating to any preceding under this Act available at the time of examination by the [Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or] Commissioner; (c) Where any order referred to in this sub-section and passed by the Assessing Officer [or the Transfer Pricing Officer, as the case may be,]had been the subject matter of any appeal [filed on or before or after the 1st day of June, 1988], the powers of the * [Principal Commissioner or]Commissioner under this sub-section shall extend [and shall be deemed always to have extended]to such matters as had not been considered and decided in such appeal.]

[Explanation 2. – For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer [or the Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,- (a)the order is passed without making inquiries or verification which should have been made; (b)the order is passed allowing any relief without inquiring into the claim; (c) the order has not been made in accordance with any order, direction or instruction issued by the Board under section 119; or (d)the order has not been passed in accordance with any decision which is prejudicial to the assessee, rendered by the jurisdictional High Court or Supreme Court in the case of the assessee or any other person.

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 14 of 30 [Explanation 3.—For the purposes of this section, “Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed.]

(3) Not withstanding anything contained in sub-section (2), an order in revision under this section may be passed at any time in the case of an order which has been passed in consequence of, or to give effect to, any finding or direction contained in an order of the Appellate Tribunal, the High Court or the Supreme Court.

Explanation. -In Computing the period of limitation for the purposes of sub- section (2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded.

7.5 On plain reading of the aforesaid provisions of the Act, it is very apparent that the ld. PCIT may call for and examine the record of any proceeding under the Act and if he considers that any order passed therein by the AO is erroneous in so far as it is prejudicial to the interests of the revenue, the ld. PCIT may after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass an order enhancing or modifying the assessment or cancelling the assessment and directing a fresh assessment. This provision was the subject matter of interpretation by the Apex Court in the case of Malabar Industrial Co. Ltd. v. CIT [2000] 243 ITR 83/109 Taxman 66 (SC), where the Supreme Court has held as under:-

"A bare reading of this provision makes it clear that the prerequisite to the exercise of jurisdiction by the Commissioner suomotu under it, is that the order of the Income-Tax Officer is erroneous in so far as it is prejudicial to the interests of the Revenue. The Commissioner has to be satisfied of twin conditions, namely, (i) the order of the Assessing

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 15 of 30 Officer sought to be revised is erroneous; and (ii) it is prejudicial to the interests of the Revenue. If one of them is absent - if the order of the Income Tax Officer is erroneous but is not prejudicial to the Revenue or if it is not erroneous but is prejudicial to the Revenue recourse cannot be had to section 263(1) of the Act.

The phrase "prejudicial to the interests of the Revenue" is not an expression of art and is not defined in the act. Understood in its ordinary meaning it is of wide import and is not confined to loss of tax''.." "'..The scheme of the Act is to levy and collect tax in accordance with the provisions of the Act and this task is entrusted to the Revenue. If due to an erroneous order of the Income-tax Officer, the Revenue is losing tax lawfully payable by a person, it will certainly be prejudicial to the interests of the Revenue. The phrase "prejudicial to the interest of the Revenue" has to be read in conjunction with an erroneous order passed by the Assessing Officer. Every loss of revenue as a consequence of an order of the Assessing Officer cannot be treated as prejudicial to the interests of the Revenue. For example, when an Income Tax Officer adopted one of the courses permissible in law and it has resulted in loss of Revenue; or where two views are possible and the Income Tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interest of the Revenue, unless the view taken by the Income Tax Officer is unsustainable in law. It has been held by this Court that where a sum not earned by a person is assessed as income in his hands on his so offering, the order passed by the Assessing Officer accepting the same as such will be erroneous and prejudicial to the interests of the Revenue."

7.6 In the case of DawjeeDadabhoy & Co. v. S.P. Jain [1957] 31 ITR 872 (Cal.) explaining the meaning of the words prejudicial to the interest of the revenue it was held as under:

"The words, "prejudicial to the interests of the revenue", have not been defined, but it must mean that the orders or assessment challenged are such as are not in accordance with law, in consequence whereof the lawful revenue due to the State has not been realised or cannot be realised. It can mean nothing else."

7.7 Thus, we are of the considered opinion that the ld. Principal Commissioner gets the jurisdiction to revise any proceedings under this Act if he considers that any order passed therein by the

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 16 of 30 Assessing Officer is erroneous insofar as it is prejudicial to the interest of the Revenue. Therefore, it is clear that the ld. PCIT cannot exercise the power of revision solely on the ground that the order passed is erroneous. The ld. PCIT gets jurisdiction only if such erroneous order is also prejudicial to the interest of the Revenue. Prejudicial to the Revenue means, lawful revenue due to the State has not been realized or cannot be realized. In other words, by the order of the Assessing Authority if the lawful revenue to the Government has not been realized or cannot be realized, as the said order is prejudicial to the interest, of the Revenue and also erroneous, the ld. PCIT gets jurisdiction to interfere with the said order under section 263. Therefore, for attracting section 263, the condition precedent is (a) the order of Assessing Officer sought to be revised is erroneous and (b) it is prejudicial to the interest of the Revenue. If one of them is absent, i.e., if the order of the Income tax officer is erroneous but is not prejudicial to the Revenue, recourse cannot be had to section 263(1) of the Act. The satisfaction of both the conditions stipulated in the section is sine qua non for the Commissioner to exercise his jurisdiction under section 263 of the Act.

7.8 Further, the term ‘erroneous’ has not been defined under the Act. The Apex Court in the above case also held that an incorrect assumption of facts or an incorrect application of law will satisfy the requirement of the order being erroneous. In the same category fall orders passed without applying the principles of natural justice or without application of mind. Further, the phrase 'prejudicial to the interests of the revenue' is not an expression of art and is also not defined in the Act. The various High Courts have treated loss of tax as prejudicial to the interests of the revenue. If due to an erroneous order of the AO, the revenue is losing tax lawfully payable by a person, it will certainly be prejudicial to the interests of the

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 17 of 30 revenue. The phrase 'prejudicial to the interests of the revenue' has to be read in conjunction with an erroneous order passed by the Assessing Officer. Every loss of revenue as a consequence of an order of the Assessing Officer cannot be treated as prejudicial to the interests of the revenue. There must be some grievous error in the Order passed by the AO, which might set a bad trend or pattern for similar assessments, which on abroad reckoning, the Commissioner might think to be prejudicial to the interests of Revenue Administration. Further, what is erroneous and prejudicial to the interest of the revenue is judicially tested by plethora of decisions however, the scope was further extended by introduction of explanation 2 to section 263 which is inserted by the Finance Act, 2015 with effect from 01/06/2015. This explanation empowers the PCIT from 01.06.2015 to invoke the provision of section 263 to the assessment order to be erroneous in so far as it is prejudicial to the interest of the revenue, if, in the opinion of the Principal CIT,- (a) the order is passed without making inquiries or verification which should have been made; (b) the order is passed allowing any relief without inquiring into the claim; (c) the order has not been in accordance with any order, direction or instruction issued by the Board under section 119;or (d) the order has not been passed in accordance with any decision which is prejudicial to the assessee, rendered by the jurisdictional High Court or Supreme Court in the case of the assessee or any other person.”

7.9 The Hon’ble High Court of Delhi in the case of Commissioner of Income-tax-XIII v. Ashish Rajpal reported in (Del-HC) (2010) 320 ITR 674 had remarkably extracted the parameters and principles laid down by the Courts which govern the exercise power by the Commissioner under the provisions of section 263 of the Act:-

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The power is supervisory in nature, whereby the Commissioner can call for (i) and examine the assessment records. The Commissioner can revise the assessment order if the twin conditions (ii) provided in the Act are fulfilled, that is, that the assessment order is not only erroneous but is also prejudicial to the interest of the revenue. The fulfilment of both the conditions is an essential prerequisite. [See Malabar Industrial Co. Ltd. v. CIT [2000] 243 ITR 83 (SC)]. An order is erroneous when it is contrary to law or proceeds on an incorrect (iii) assumption of facts or is in breach of principles of natural justice or is passed without application of mind, that is, is stereo-typed, inasmuch as, the Assessing Officer, accepts what is stated in the return of the assessee without making any enquiry called for in the circumstances of the case, that is, proceeds with 'undue haste'. [See Gee Vee Enterprises v. Addl. CIT [1975] 99 ITR 375 (Delhi)]. The expression "prejudicial to the interest of the revenue" while not to be (iv) confused with the loss of tax will certainly include an erroneous order which results in a person not paying tax which is lawfully payable to the revenue. [See Malabar Industrial Co. Ltd.'s case (supra)].

(v) Every loss of tax to the revenue cannot be treated as being "prejudicial to the interest of the revenue". For example, when the Assessing Officer takes recourse to one of the two courses possible in law or where there are two views possible and the Commissioner does not agree with the view taken by the Assessing Officer which has resulted in a loss. [See CIT v. Max India Ltd. [2007] 295 ITR 282 (SC)].

(vi) There is no requirement of issuance of a notice before commencing proceedings under section 263 of the Act. What is required is adherence to the principles of natural justice by granting to the assessee an opportunity of being heard before passing an order under section 263. [See Electro House's case (supra)].

(vii) If the Assessing Officer acts in accordance with law his order cannot be termed as erroneous by the Commissioner, simply because according to him, the order should have been written 'more elaborately'. Recourse cannot be taken to section 263 to substitute the view of the Assessing Officer with that of the Commissioner. [See CITv. Gabriel India Ltd. [1993] 203 ITR 108 (Bom.)].

(viii) The exercise of statutory power under section 263 of the Act is dependent on existence of objective facts ascertained from prima faciematerial on record. The evaluation of such material should show that tax which was lawfully exigible was not imposed. [See Gabriel India Ltd.'s case (supra)].

7.10 Now, in the light of the above principles laid down by the Hon’ble Apex Court & Hon’ble Delhi High Court, it is apposite here

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 19 of 30 to first examine whether the AO passed an assessment order without making inquiries or verification or the order had not been passed in accordance with any decision which is prejudicial to the assessee rendered by the Jurisdictional High Court or Supreme Court as alleged by the ld. PCIT in the revision Order. The facts in brief as observed by the AO are that the assessee is a registered Co- operative Society engaged in the business of providing credit facility to its members. For the AY 2022-23, the assessee society filed its return of income on 13.08.2022 by declaring total income of Rs.1,14,450/- after claiming deduction u/s. 80P of the Act. When we grabbed a look at the assessment order passed by the AO, we noticed that the AO after due verification & examining the submissions/explanation in detail along with the documentary evidences etc. did not draw any adverse inference in respect of the issues for which the case was selected for Scrutiny under CASS. Further, the AO while passing the assessment Order had categorically observed that the assessee society filed its written submission with relevant documents and after considering all the written submissions, the assessment is being completed accepting the returned income.

7.11 Further, we take note of the fact that the assessee society in its reply contended before the ld. PCIT that the assessee society had claimed deductions u/s 80P of the Act as all its incomes are from carrying on its business activities with the members only, and hence the profit generated by these activities is fully deductible. The assessee society also submitted that as the society is engaged in carrying on the business of banking and providing credit facilities to its members as envisaged in section 80P of the Act, they have claimed the deduction for entire amount under section 80P(2) of the Act only. Further, it was submitted that the earnings of the society i.e. interest income, Service charges, Nominal Member fees, Late

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 20 of 30 fees, Dividend etc. are attributable to the activity of “providing credit facility to its members” and hence the deduction was rightly claimed under section 80P(2) of the Act. Lastly, the assessee society submitted that the assessee being a Credit Co-operative Society and providing credit facilities to members are rightly eligible to claim deduction u/s 80P(2) of the Act.

7.12 Finally, the AO after considering & examining the details/written submission /explanation concluded the assessment proceedings by accepting the returned income. Therefore, we are of the considered opinion that it is not a case that the AO had passed an order of assessment without making any inquiries or verification and accordingly the allegation of the ld. PCIT that the AO had failed to examine and verify the issue of interest is not at all tenable. Where the enquiry had been conducted and the AO had reached a particular conclusion, though reference to such enquiries had not been made in the order of Assessment, it was apparent from the record, without any thing to show how & why the enquiry conducted by the AO was not in accordance with law, the invocation of jurisdiction by the ld. PCIT is unsustainable. The Assessing Officer while passing an order of assessment performed quasi Judicial function, applies his mind judiciously based on the facts & circumstances of the case for the purpose of protecting the interest of revenue. In the present case the AO after calling for the details/ explanation/evidence & after making proper enquiries or verification came to the conclusion that no adverse inference is drawn with respect to the issues selected for complete scrutiny. However, the ld. PCIT holds that the assessing officer had not conducted necessary inquiries or verification and not made the additions of interest income under the head “income from other sources” as per the decision of the Apex court & Jurisdictional High Court & thereby invoked clause (a) of the Explanation-2 of section

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 21 of 30 263 of the Act. No doubt clause (a) of the above explanation deems the order to be erroneous and prejudicial to the interest of the revenue in case order is passed without making enquiries or verification which should have been made in the opinion of the Principal Commissioner or Commissioner; however we observed that the AO passed an Order of assessment after making inquiries or verification and taken a plausible view. As discussed earlier the Assessing Officer in the order of assessment is not required to give detailed reasoning in respect of each and every item of deduction and therefore, the question whether there has been an application of mind before allowing deduction has to be examined from the record of the case.The question of lack of enquiry / inadequate enquiry is also required to be kept in mind and mere inadequacy of the enquiry would not confer jurisdiction on the Commissioner of Income Tax under Section 263 of the Act. In this regard we respectfully rely on the judgement of the Hon’ble High court of Karnataka in the case of The Commissioner of Income Tax v. M/s Chemsworth Pvt. Ltd Reported in (2020) 275 TAXMAN 408 which has held as under-

“6. Thus, from close scrutiny of Section 263 it is evident that twin conditions are required to be satisfied for exercise of revisional jurisdiction under Section 263 of the Act firstly, the order of the Assessing Officer is erroneous and secondly, that it is prejudicial to the interest of the revenue on account of error in the order of assessment.

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 22 of 30 RAJASTHAN AND ORS.', CIVIL APPEAL NO.2773/2020 DECIDED ON 17.07.2020. 8. In the backdrop of aforesaid well settled legal principles, we may examine the facts of the case in hand. In 'CIT VS. SUNBEAM AUTO LTD.', 332 ITR 167, it has been held by Delhi High Court that Assessing Officer in the order of assessment is not required to give detailed reasoning in respect of each and every item of deduction and therefore, the question whether there has been an application of mind before allowing expenditure has to be examined from the record of the case. The question of lack of enquiry / inadequate enquiry is also required to be kept in mind and mere inadequacy of the enquiry would not confer jurisdiction on the Commissioner of Income Tax under Section 263 of the Act. In the instant case, the Commissioner of Income Tax has held that the enquiry conducted by the Assessing Officer is inadequate and has assumed the revisional jurisdiction. The assessee has filed all the details before the Assessing Officer and Assessing Officer has accepted the contention of the assessee that no expenditure is attributable to the exempt income during the relevant Assessment Year. Thus, while recording the aforesaid finding, the Assessing Officer has taken one of the plausible views in allowing the claim of the assessee and therefore, the Commissioner of Income Tax could not have set aside the order of assessment merelyon the ground of inadequacy of enquiry, the order passed by the Commissioner of Income Tax is not sustainable in law and the same has rightly been set aside by the Tribunal.

In view of preceding analysis, the substantial question of law framed by this court is answered against the revenue and in favour of the assessee.”

7.13 Thus, in the present case also the ld. PCIT had held that the enquiry conducted by the AO is not proper and assumed the revisional jurisdiction. The assessee society in the present case had filed all the details along with the written submissions & the AO had accepted the contention of the assessee that the interest received from Co-operative Bank/Commercial banks are attributable to the business of the assessee & accordingly allowed deduction u/s 80P(2) of the Act. Thus, the AO has taken a plausible view in allowing the claim of the assessee and therefore, in our considered opinion the ld. PCIT could not have set aside the order of assessment merely on the ground of inadequacy of enquiry, the order passed by the ld. PCIT is not sustainable in law.

7.14 Now coming to the allegation of the ld. PCIT that clause (d) of the explanation-2 of section 263 is also attracted in the instant

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 23 of 30 case. Undisputedly, clause (d) of the above explanation deems the order to be erroneous and prejudicial to the interest of the revenue in case order has not been passed in accordance with any decision which is prejudicial to the assessee, rendered by the jurisdictional High Court or Supreme Court in the case of the assessee or any other person. We are of the considered opinion that in the present case the clause (d) of the explanation-2 of section 263 is also not applicable in the present case as the AO had passed an assessment order by taking a plausible view also supported by the various judgments of Hon’ble High Court of Karnataka. Further, we are also of the considered opinion that if two views were possible and the AO had taken one of the views, then also the same could not have been interfered with. Section 263 of the Act does not visualize a case of substitution of the judgment of the Commissioner for that of the subordinate authority who passed the order which is sought to be revised. The Order passed by a subordinate authority in exercise of its quasi-judicial power vested in him in accordance with law, cannot be termed erroneous merely because the Commissioner does not feel satisfied with the conclusions reached.

7.15 The following are the judgments of the Jurisdictional High Court in favour of the assessee which held that interest received by Co-operative Society from Co-operative Banks/Commercial Banks are attributable to the business of the assessee and accordingly allowed the deduction u/s 80P(2)(a)(i) of the Act-

1) Tumkur Merchants Souharda Credit Cooperative Ltd. v. Income-tax officer Ward-V, Tumkur reported in [2015] 230 Taxman 309

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 24 of 30 2) Lalitamba Pattina Souharda sahakari Niyamita v. The ITO in ITA No.100004 of 2018 dated 19/02/2018.

3) Guttigedarara Credit Co-operative Society Ltd. v. Income-tax Officer, Ward 2(2), Mysore(2015) 377 ITR 464

7.16 However on the other hand there are certain judgments of the same Jurisdictional High Court which held that the interest received from Co-operative Bank/Commercial Bank are liable to tax u/s 56 of the Act under the head “ Income from other Sources” & these interest are even not liable for deduction even u/s 80P(2)(d) of the Act. These judgments are detailed below-

1) Pr. CIT v. Totagars Co-operative Sale Society (2017) 395 ITR 611 2) M/s Judicial Employees House Building Cooperative Society Limited v. Income Tax Officer in ITA No. 93/2024 dated 16/09/2025. 3) Bangalore Credit Co-operative Society Limited v. Income Tax Officer in ITA No. 184 & 185/2025 dated 05/03/2026.

7.17 Thus, the point of discussing all above is that undisputedly the issue is debatable & the AO had taken one of the possible views. As can be seen that the view taken by the AO was a plausible view & it is also not a case that the view taken by him is unsustainable in law & therefore the same could not have been interfered with. Further, the Hon’ble Supreme Court in the case of Commissioner of Customs (import) v. Dilip Kumar & Co [2018] 95 taxmann.com 327 / [2018] 9 SCC 1 held that if there are two views possible in the matter of interpretation of a charging section, the one favourable to the assessee needs to be applied. Applying the aforesaid ratio in the present fact of the case, we find no fault with the AO in taking the plausible view of treating the interest chargeable u/s 28 of the Act

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 25 of 30 being attributable to the business of the assessee & allowed the deduction claimed u/s 80P(2) of the Act.

7.18 Further, when we look at the decision of the Hon’ble Supreme Court in the case of Totgars Co-operative Sale Society Ltd. V. Income Tax Officer reported in [2010] 188 Taxman 282/ 322 ITR 283 (SC) heavily relied upon by the ld. PCIT as well as the ld. DR, the Hon’ble Supreme Court was dealing with a case where the assessee therein, apart from providing credit facilities to the members, was also in the business of marketing of agricultural produce grown by its members. The sale consideration received from marketing agricultural produce of its members was retained in many cases. The said retained amount payable to its members from whom the produce bought was invested in a short-term deposit/security. Such amount retained by the assessee therein was a liability and it was shown in the balance sheet on the liability side. Therefore, to that extent, such interest income cannot be said to be attributable either to the activity mentioned in section 80P(2)(a)(i) of the Act or under section 80P(2)(a)(iii) of the Act. On these facts Hon’ble Supreme Court held that the assessing officer was right in taxing the interest income indicated above under section 56 of the Act. Hon’ble Supreme Court , also clarified that they are confining the said judgement to the facts of that case. Therefore, the reliance placed by the ld. PCIT on the decision of Hon’ble Supreme Court in the case of Totgars Co-operative Sale Society Ltd. V. Income Tax Officer (Supra) is completely distinguishable on the facts of the present case. In holding so, we draw our support & guidance from the decision of the Hon’ble High Court of Karnataka in the case of Guttigedarara Credit Co-operative Society Ltd. v. Income-tax Officer, Ward 2(2), Mysore reported in (2015) 377 ITR 464 which held as under-

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 26 of 30 “9. The word 'attributable' used in the said Section is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 (at page 93) as under:—

'As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business of" the specified industry (here generation and distribution of electricity) on which the learned Solicitor- General relied, it will be pertinent to observe that the legislature has deliberately used the expression "attributable to" and not the expression "derived from". It cannot be disputed that the expression "attributable to" is certainly wider in import than the expression "derived from". Had the expression "derived from" been used, it could have with some force been contended that a balancing charge arising from the sale of old machinery and buildings cannot be regarded as profits and gains derived from the conduct of the business of generation and distribution of electricity. In this connection, it may be pointed out that whenever the legislature wanted to give a restricted meaning in the manner suggested by the learned Solicitor- General, it has used the expression "derived from", as, for instance, in section 80J. In our view, since the expression of wider import, namely, "attributable to", has been used, the legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity.' 10. Therefore, the word "attributable to" is certainly wider in import than the expression "derived from". Whenever the legislature wanted to give a restricted meaning, they have used the expression "derived from". The expression "attributable to" being of wider import, the said expression is used by the legislature whenever they intended to gather receipts from sources other than the actual conduct of the business. A Co-operative Society which is carrying on the business of providing credit facilities to its members, earns profits and gains of business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, the society cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains of the business of providing credit facilities to its members only. The society is not carrying on any separate business for earning such interest income. The income so derived is the amount of profits and gains of business attributable to the activity of carrying on the business of banking or providing credit facilities to its members by a co-operative society and is liable to be deducted from the gross total income under Section 80P of the Act.

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 27 of 30 cases. The said retained amount which was payable to its members from whom produce was bought, was invested in a short-term deposit/security. Such an amount which was retained by the assessee-Society was a liability and it was shown in the balance sheet on the liability side. Therefore, to that extent, such interest income cannot be said to be attributable either to the activity mentioned in Section 80P(2)(a)(i) of the Act or under Section 80P(2)(a)(iii) of the Act. Therefore in the facts of the said case, the Apex Court held the assessing officer was right in taxing the interest income indicated above under Section 56 of the Act. Further they made it clear that they are confining the said judgment to the facts of that case. Therefore it is clear, Supreme Court was not laying down any law. 12. In the instant case, the amount which was invested in banks to earn interest was not an amount due to any members. It was not the liability. It was not shown as liability in their account. In fact this amount which is in the nature of profits and gains, was not immediately required by the assessee for lending money to its members, as there were no takers. Therefore they had deposited the money in a bank so as to earn interest. The said interest income is attributable to carrying on the business of banking and therefore it is liable to be deducted in terms of Section 80P(1) of the Act. In fact similar view is taken by the Andhra Pradesh High Court in the case of CIT v. Andhra Pradesh State Co-operative Bank Ltd. [2011] 336 ITR 516/200 Taxman 220/12 taxmann.com 66.”

7.19 Thus, we can safely conclude that the view taken by the AO was a plausible view and the view taken by him also cannot be said to be passed not in accordance with the decision of the Hon’ble jurisdictional High Court or Hon’ble Supreme Court. Thus, in the given facts and circumstances of the case, two views are possible and one view has been adopted by the Assessing Officer, then that alone would not be sufficient to exercise the powers under section 263 of the Act by the Commissioner of Income-tax. In holding so we rely on the decision of the Hon’ble High Court of Karnataka in the case of Commissioner of Income-tax v. Gokuldas Exports reported in[2011] 333 ITR 214has held as under-

“15. By a long catena of judgments of various High Courts and the Supreme Court, it is too well settled that if in the given facts and circumstances of the case, two views are possible and one view has been adopted by the Assessing Officer, then that alone would not be sufficient to exercise the powers under section 263 of the Act by the Commissioner of Income-tax.

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 28 of 30 16. The phrase "prejudicial to the interests of the Revenue" under section 263 of the Act has to be read in conjunction with the expression "erroneous" order by the Assessing Officer. Every loss of revenue as a consequence of an order of the Assessing Officer cannot be treated as prejudicial to the interests of the Revenue.

7.20 Again the Hon’ble High Court of Karnataka in the case of Commissioner of Income Tax v. Aztec Software Technology Ltd reported in (2020) 428 ITR 245 had again reiterated the same & held as under- “7. The aforesaid provision was considered by the Supreme Court in Malabar Industrial Co. Ltd. v. CIT 243 ITR 43 SC and it was held that the phrase 'prejudicial to the interests of the revenue' has to be read in conjunction with an erroneous order passed by the Assessing Officer and every loss of revenue as a consequence of the order of the Assessing Officer cannot be treated as prejudicial to the interest of revenue. It was further held that where two views are possible and the Income-tax Officer has taken one view with which the Commissioner does not agree, the order passed by the Assessing Officer cannot be treated as erroneous order prejudicial to the interest of the revenue. The principles laid down in the aforesaid decision were reiterated by the Supreme Court in 'CIT v. Max India Ltd.' 295 ITR 282 (SC) and recently in 'Ultratech Cement Ltd. and ORS. v. State of Rajasthan and ORS.' [CIVIL APPEAL No. 2773/2020 decided on 17-7-2020]. 8. In view of aforesaid enunciation of law, the facts of the case may be seen. The assessee is engaged in the business of computer software development and services. The expenditure incurred in foreign currency on traveling, professional charges and onsite service charges are for development of software at clients site

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 29 of 30 outside India, the assessee has neither rendered any technical services nor has earned any receipt from rendering technical services. Therefore, there is no need to exclude the expenditure incurred in foreign currency from the export turnover. [SEE: 'Patani Telecom (P.) Ltd. v. ITO' [2008] 22 SOT 26 (Hyd.) and 'Chancepond Technologies (O) Ltd. v. Asst. CIT' [2008] 22 SOT 220 (Chennai)]. Thus, the view taken by the Assessing Officer was a plausible view and the view taken by him cannot be said to be erroneous. Therefore, in view of well settled legal position, invocation of powers in the fact situation of the case under section 263 of the Act could not have been held to be justified. The Tribunal has therefore, rightly set aside the order passed by the Commissioner of Income-tax (Appeals).

In view of preceding analysis, substantial questions of law framed by this court are answered against the revenue and in favour of the assessee.”

7.21 Further, the Apex court in the case of Commissioner of Income-tax (Central), Ludhiana v. Max India Ltd reported in (2007) 295 ITR 282 again reiterated that where two views are possible and the Income-tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interest of the revenue, unless the view taken by the Income-tax Officer is unsustainable in law. The relevant Para are reproduced as under:- “2. At this stage we may clarify that under para 10 of the judgment in the case of Malabar Industrial Co. Ltd. (supra) this Court has taken the view that the phrase "prejudicial to the interest of the revenue" under section 263 has to be read in conjunction with the expression "erroneous" order passed by the Assessing Officer. Every loss of revenue as a consequence of an order of the Assessing Officer cannot be treated as prejudicial to the interest of the revenue. For example, when the Income-tax Officer adopted one of the courses permissible in law and it has resulted in loss of revenue; or where two views are possible and the Income- tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interest of the revenue, unless the view taken by the Income-tax Officer is unsustainable in law.----------"

7.22 In view of the above discussion & respectfully following the decisions of the Hon’ble jurisdictional High Court as well as Hon’ble Supreme Court, we held that the assessment order dated 18.03.2024 passed by the assessing officer is neither erroneous nor

ITA No.181/Bang/2026 SoubhagyalaxmiVividhoddeshaSouhardaSahakara Sangha Niyamitha, Koppala Page 30 of 30 prejudicial to the interest of the revenue and accordingly we annul the order passed by the ld. PCIT, Hubli u/s 263 of the Act.

Order pronounced in the open court on 30th July, 2026

Sd/- Sd/- (Prashant Maharishi) (Keshav Dubey) Vice President Judicial Member

Bangalore, Dated 30th July, 2026. VG/SPS

Copy to:

Asst. Registrar, ITAT, Bangalore.