SHREE MOOKAMBIKA VIVIDODDESHA SOUHARDHA SAHAKARI LTD., ,UDUPI vs. INCOME TAX OFFICER, WARD-1 & TPS, UDUPI

ITA 2522/BANG/2025Status: DisposedITAT Bangalore31 August 2026AY 2017-186 pages
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What did the Tribunal hold?

The Tribunal held that an assessee registered under the Karnataka Souharda Sahakari Act, 1997, is to be treated as a co-operative society for the purpose of Section 80P. It also found that the principle of mutuality was not lost as the assessee dealt only with its members.

What were the facts?

The assessee, a Souharda Sahakari, claimed deduction under Section 80P(2)(a)(i) for its credit facilities business. The Assessing Officer and CIT(A) denied this deduction, arguing it was not a co-operative society and the principle of mutuality was lost due to associate members.

What were the issues?

Whether a Souharda Sahakari registered under the Karnataka Souharda Sahakari Act is eligible for deduction under Section 80P, and whether the principle of mutuality is lost due to associate members.

Which sections of the Income-tax Act were involved?

Section 80P,Section 143(3),Section 2(19)

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 SHRI PRASHANT MAHARISHI, VICE PRESIDENT

1.

ITA No. 2522/Bangalore/2025, relating to assessment year 2017–18, has been filed by Shree Moorambika Vividodesha Souhradra Sahakari Limited (the assessee/appellant) against the appellate order dated 30 June 2025 passed by the Joint Commissioner of Income Tax (Appeals)–2, Surat (the learned CIT(A)). By that order, the CIT(A) dismissed the assessee’s appeal against the assessment order passed under section 143(3) of

The order continues below.

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