THE KARNATAKA STATE COOPERATIVE AGRICULTURE AND DEVELOPMENT BANK LIMITED,BANGLAORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

ITA 1821/BANG/2025Status: DisposedITAT Bangalore09 April 2026AY 2022-2338 pages
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What did the Tribunal hold?

The Tribunal held that enhanced business income arising from disallowances of expenditure is eligible for deduction under Section 80P(2)(a)(i), following a previous ITAT decision and CBDT circular.

What were the facts?

The assessee, a cooperative society, claimed deduction under Section 80P on income from investments and other advances. The AO disallowed a portion of this claim, treating it as income from other sources. The CIT(A) confirmed the disallowance.

What were the issues?

Whether income enhanced due to disallowances of expenditure is eligible for deduction under Section 80P, and whether interest on investments and other advances by a cooperative society are eligible for deduction.

Which sections of the Income-tax Act were involved?

Section 80P,Section 56,Section 36(1)(va)

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Income Tax Appellate Tribunal, ‘B’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Shri Bhardwaj Sheshadri, Advocate &, Shri K Sheshadri, CA
For Respondent: Shri Subramanian, JCIT (DR)
Hearing: 12.01.2026Pronounced: 09.04.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

The present appeal, at the instance of the assessee, is directed against the order passed under section 250 of the Income Tax 1961 and is pertaining to A.Y. 2022-23 by the learned Commissioner of Income Tax Appeal (hereafter the learned CIT(A)) at National Faceless Appeal Centre-NFAC bearing DIN: ITBA/NFAC/S/250/2025-26/1077045835(1).

2.

The assessee in the memo of appeal has raised as many as 10 grounds of appeal. However, all the grounds raised are interconnected and effectively 2 issued raised therein.

3.

The first issue raised by th

The order continues below.

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