THE DHANDOWAL COOPERATIVE AGRI MULTI -PURPOSE SOCIETY LIMITED,SHAHKOT vs. INCOME TAX OFFICER WARD, NAKODAR

ITA 415/ASR/2025Status: DisposedITAT Amritsar31 August 2026AY 2016-1712 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal allowed the deduction under Section 80P(2)(d). It followed the jurisdictional High Court's decision in CIT vs. Doaba Cooperative Sugar Mills Ltd., which held that the source of investment is not relevant for claiming deduction as long as it's with another cooperative society.

What were the facts?

The assessee, a cooperative agricultural multipurpose society, claimed deduction under Section 80P(2)(d) for interest earned on investments made with a cooperative bank. The Assessing Officer disallowed this claim, treating the interest as income from other sources. The CIT(A) upheld the disallowance, relying on the Supreme Court decision in Totgar's Cooperative Sale Society Ltd.

What were the issues?

Whether interest income earned by a cooperative society from investments in a cooperative bank is eligible for deduction under Section 80P(2)(d) of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

Section 80P(2)(d),Section 56,Section 80P(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. S. RIFAUR RAHMAN & SH. UDAYAN DAS GUPTA

Hearing: 23.07.2026Pronounced: 31.08.2026

Per: Udayan Dasgupta, JM: This appeal is filed by the assessee against the order of ld. CIT(A), NFAC, Delhi, passed u/s 250 of the IT Act, 1961, dated 20.03.2025, which has emanated from the order of the AO, passed u/s 147 r.w.s. 144B of the Act, dated 05.02.2024. 2. Grounds of appeal taken in Form 36 are as follows:

“1. That the order of Ld. Commissioner of Income Tax (Appeals)- NFSC Delhi, is against law & facts of the case.

2.

That the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi has erred in law & facts of the case in confirming the addition of Rs.22,01,918/- to the returned income. Assessment Year: 2016-17 2

3.

That the Ld. Commissioner of Income Tax (App

The order continues below.

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