MSEB ENGINEERS COOP CREDIT SOCIETY LTD,NAGPUR vs. ITO WARD 1(3), NAGPUR, NAGPUR

ITA 312/NAG/2026Status: DisposedITAT Nagpur14 July 2026AY 2020-218 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that interest earned on deposits made from operational or statutory funds, which are intrinsically connected with the business of providing credit facilities to members, is attributable to the assessee's business activity. Therefore, such interest income is eligible for deduction under Section 80P(2)(a)(i).

What were the facts?

The assessee, a cooperative credit society, earned interest on bank deposits. The Assessing Officer and CIT(A) treated this interest as income from other sources, denying deduction under Section 80P(2)(a)(i). The assessee argued the deposits were operational funds and the interest was linked to its core business.

What were the issues?

Whether interest earned by a cooperative society on bank deposits, made from operational funds, is eligible for deduction under Section 80P(2)(a)(i) as income from its business of providing credit facilities.

Which sections of the Income-tax Act were involved?

Section 80P(2)(a)(i),Section 250,Section 143(3),Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR

Before: SHRI ANUBHAV SHARMA & SHRI KHETTRA MOHAN ROY

For Appellant: Shri Ameenuddin Khan, Adv. &, Shri Mahavir Atal, CA
For Respondent: Shri Surjit Kumar Saha, Sr.DR
Hearing: 15.06.2026Pronounced: 14.07.2026

PER KHETTRA MOHAN ROY, AM:

These three appeals filed by the same assessee are directed against the separate orders of National Faceless Appeal Centre, Delhi, (for short, “CIT(A)”), dated 18.02.2026, 21.01.2026 & 03.03.2026 respectively passed under section 250 of the Income Tax Act, 1961 (for short, “Act”) which are emanating from the different assessment

ITA Nos. 311-313/NAG/2026 (MSEB Engineers Co-op. Cr. Society Ltd.) orders dated 17.03.2021, 21.09.2022 & 15.03.2024 passed u/s. 143(3) r.w.s. 144B of the Act for the Assessment Years (AYs) 2018-19, 2020-21 & 2022-23 respectively.

2.

The common grievance of

The order continues below.

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