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Facts
The assessee, a co-operative housing society, claimed a deduction of Rs. 12,05,883/- on interest income earned from cooperative banks. The Assessing Officer disallowed this claim, and the CIT(A) upheld the disallowance. The assessee appealed to the Tribunal.
Held
The Tribunal held that if a cooperative bank is not carrying out banking business as defined under the Banking Regulation Act, it should be considered a cooperative society eligible for deduction under Section 80P(2)(d). If it is carrying out banking business, the deduction would be denied.
Key Issues
Whether interest income earned from cooperative banks is eligible for deduction under Section 80P(2)(d) of the Income Tax Act, considering the amendments and judicial pronouncements on cooperative banks.
Sections Cited
80P(2)(d), 143(1), 139(1), 80P(4), 194A(3)(v), 5(b), 80P(2)(a)(i)
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Income Tax Appellate Tribunal, MUMBAI BENCH “H (SMC
Before: SHRI OM PRAKASH KANT & SHRI RAHUL CHAUDHARY
This appeal by the assessee is directed against order dated 31.08.2024 passed by the Ld. Commissioner of Income-tax (Appeals) [in short ‘the Ld. CIT(A)’] for assessment year 2021-22, raising following grounds:
Disallowance of Rs. 12,05,880 u/s. 80P(2)(d) of the Act being Interest Income derived from Cooperative Banks :
The Id C.I.T. (Appeals) erred in upholding the The Id C.I.T. (Appeals) erred in upholding the Intimation Order Intimation Order u/s 143 (1) dated 30/09/2022 disallowing a sum of Rs. u/s 143 (1) dated 30/09/2022 disallowing a sum of Rs. u/s 143 (1) dated 30/09/2022 disallowing a sum of Rs. 12,05,880/- being Interest Income derived from Cooperative Banks being Interest Income derived from Cooperative Banks being Interest Income derived from Cooperative Banks without appreciating that Cooperative Banks registered under without appreciating that Cooperative Banks registered under without appreciating that Cooperative Banks registered under Maharashtra Cooperative Societies Act, 1960 are Cooperative Maharashtra Cooperative Societies Act, 1960 are Cooperative Maharashtra Cooperative Societies Act, 1960 are Cooperative Society and as such Interest Income derived by the Appellant is Society and as such Interest Income derived by the Appellant is Society and as such Interest Income derived by the Appellant is eligible for deduction U/s 80P(2)(d) of the Act. and therefore eligible for deduction U/s 80P(2)(d) of the Act. and therefore eligible for deduction U/s 80P(2)(d) of the Act. and therefore disallowance ought to be deleted. disallowance ought to be deleted.
The Id C.I.T. (A) erred in not granting the relief U/s 80P(2)(d) 2. The Id C.I.T. (A) erred in not granting the relief U/s 80P(2)(d) 2. The Id C.I.T. (A) erred in not granting the relief U/s 80P(2)(d) despite the fact that the despite the fact that the Society is eligible for Deduction under Society is eligible for Deduction under Chapter VIA r.w.s. 80AC of the Act insofar as the Return of Income Chapter VIA r.w.s. 80AC of the Act insofar as the Return of Income Chapter VIA r.w.s. 80AC of the Act insofar as the Return of Income was filed within the due date prescribed U/s was filed within the due date prescribed U/s 139(1) of the Act. 139(1) of the Act. 2. Briefly stated, facts of the case are that the assessee filed its Briefly stated, facts of the case are that the assessee filed its Briefly stated, facts of the case are that the assessee filed its return of income on 28.02.2022 declaring total income at on 28.02.2022 declaring total income at Rs.12,110/- after claiming deduction of Rs.12,05,883/ after claiming deduction of Rs.12,05,883/- in respect after claiming deduction of Rs.12,05,883/ of interest from the Co of interest from the Co-operative Bank in terms of section 80P(2)(d) operative Bank in terms of section 80P(2)(d) of the Income-tax Act, 1961 (in short ‘the Act’). The return was tax Act, 1961 (in short ‘the Act’). The return was tax Act, 1961 (in short ‘the Act’). The return was processed by the Central Processing Centre, Bengluru and in the e Central Processing Centre, Bengluru and in the e Central Processing Centre, Bengluru and in the intimation order passed u/s 143(1) of the Act, t passed u/s 143(1) of the Act, the CPC denied claim he CPC denied claim of deduction u/s 80P(2)(d) of the Act. Aggrieved, the assessee filed of deduction u/s 80P(2)(d) of the Act. Aggrieved, the assessee filed of deduction u/s 80P(2)(d) of the Act. Aggrieved, the assessee filed appeal before the Ld. CIT(A) and submitted that issue in dispute appeal before the Ld. CIT(A) and submitted that issue in dispute appeal before the Ld. CIT(A) and submitted that issue in dispute was covered in favour of the assessee by way of various decisions of overed in favour of the assessee by way of various decisions of overed in favour of the assessee by way of various decisions of the Co-ordinate Benches of the Tribunal ordinate Benches of the Tribunal, but the Ld. CIT(A) rejected but the Ld. CIT(A) rejected the contention that interest received from co the contention that interest received from co-operative bank was operative bank was eligible for deduction for the reason that those co eligible for deduction for the reason that those co-operat operative banks are primarily co-operative society. The relevant finding of the Ld. operative society. The relevant finding of the Ld. operative society. The relevant finding of the Ld. CIT(A) is reproduced as under: CIT(A) is reproduced as under:
“5.1.The Ground No. 1 of appeal is related to the non 5.1.The Ground No. 1 of appeal is related to the non 5.1.The Ground No. 1 of appeal is related to the non-allowability of deduction under Section 80P by the order u/s 143(1) passed by of deduction under Section 80P by the order u/s 143(1) passed by of deduction under Section 80P by the order u/s 143(1) passed by CPC with intimation date of 30.09.2022. The appellant has CPC with intimation date of 30.09.2022. The appellant has CPC with intimation date of 30.09.2022. The appellant has claimed an amount of Rs. 12,05,883/ claimed an amount of Rs. 12,05,883/- as deduction under Section as deduction under Section 80P of the Act. However, this deduction was disallowed in the of the Act. However, this deduction was disallowed in the of the Act. However, this deduction was disallowed in the above-mentioned order. mentioned order. 5.2. The appellant has claimed deduction under Section 80P. The 5.2. The appellant has claimed deduction under Section 80P. The 5.2. The appellant has claimed deduction under Section 80P. The relevant part of the Act is being reproduced below: relevant part of the Act is being reproduced below: "80P(1) Where in the case of an assessee being a cooperati "80P(1) Where in the case of an assessee being a cooperati "80P(1) Where in the case of an assessee being a cooperative society, the gross total income includes any income referred to un society, the gross total income includes any income referred to un society, the gross total income includes any income referred to un sub-section (2), there shall be deducted, in accordance with and section (2), there shall be deducted, in accordance with and section (2), there shall be deducted, in accordance with and subject to the provisions of this section, the sums specified in sub subject to the provisions of this section, the sums specified in sub subject to the provisions of this section, the sums specified in sub- section (2), in computing the total income of the as section (2), in computing the total income of the assessee. sessee. * (2) The sums referred to in sub * (2) The sums referred to in sub-section (1) shall be the following section (1) shall be the following namely:- ….. (d). In respect of any income by way of interest or dividend derived (d). In respect of any income by way of interest or dividend derived (d). In respect of any income by way of interest or dividend derived by the cooperative society from its investments with any other by the cooperative society from its investments with any other by the cooperative society from its investments with any other cooperative society, the whole of cooperative society, the whole of such income. 5.3. Whereas the entity mentioned in the Section 80P(2)(d) is 5.3. Whereas the entity mentioned in the Section 80P(2)(d) is 5.3. Whereas the entity mentioned in the Section 80P(2)(d) is Cooperative Society, but the appellant has claimed deduction for Cooperative Society, but the appellant has claimed deduction for Cooperative Society, but the appellant has claimed deduction for the interest earned from a Cooperative Bank. From the documents the interest earned from a Cooperative Bank. From the documents the interest earned from a Cooperative Bank. From the documents submitted submitted submitted during during during the the the proceedings, proceedings, proceedings, it it it is is is noted noted noted that that that the t t corresponding banks are (i) NKGSB Co corresponding banks are (i) NKGSB Co-operative Bank (ii) SVS operative Bank (ii) SVS Cooperative Bank Ltd iii) Maharashtra State Cooperative Bank (iv) Cooperative Bank Ltd iii) Maharashtra State Cooperative Bank (iv) Cooperative Bank Ltd iii) Maharashtra State Cooperative Bank (iv) Saraswat Cooperative Bank. The Saraswat Cooperative Bank. The appellant has relied upon many appellant has relied upon many judicial pronouncements from different benches of Hon'ble ITAT judicial pronouncements from different benches of Hon'ble ITAT judicial pronouncements from different benches of Hon'ble ITAT claiming that since the Cooperative banks are also registered laiming that since the Cooperative banks are also registered laiming that since the Cooperative banks are also registered under Cooperative Societies Act therefore, they are also same as under Cooperative Societies Act therefore, they are also same as under Cooperative Societies Act therefore, they are also same as Cooperative societies for the purposes of Income Tax Act 1961, and Cooperative societies for the purposes of Income Tax Act 1961, and Cooperative societies for the purposes of Income Tax Act 1961, and more particularly Section 80P (2)(d). more particularly Section 80P (2)(d). 5.4.In the case of appell 5.4.In the case of appellant, it is important to note 2 amendments ant, it is important to note 2 amendments brought to the Act with respect to the status of Cooperative banks. brought to the Act with respect to the status of Cooperative banks. brought to the Act with respect to the status of Cooperative banks. Section 80P(4) was introduced vide Finance Act 2006 w.e.f. from Section 80P(4) was introduced vide Finance Act 2006 w.e.f. from Section 80P(4) was introduced vide Finance Act 2006 w.e.f. from 01.04.2007. The relevant part of the Act is being reproduced 01.04.2007. The relevant part of the Act is being reproduced 01.04.2007. The relevant part of the Act is being reproduced below: "(4) . The pro "(4) . The provisions of this Section shall not apply in relation to visions of this Section shall not apply in relation to any co-operative bank other than a primary agricultural, credit operative bank other than a primary agricultural, credit operative bank other than a primary agricultural, credit society society society of of of a a a primary primary primary cooperative cooperative cooperative agricultural agricultural agricultural and and and rural rural rural development bank." development bank."
The other is, the amendment of Section 194A(3)(v) of the Act The other is, the amendment of Section 194A(3)(v) of the Act The other is, the amendment of Section 194A(3)(v) of the Act excluding the Cc... operative banks from the definition of Co xcluding the Cc... operative banks from the definition of Co xcluding the Cc... operative banks from the definition of Co- operative society by Finance Act, 2015. operative society by Finance Act, 2015. (v) to such income credited or paid by a cooperative society other to such income credited or paid by a cooperative society other to such income credited or paid by a cooperative society other than a cooperative bank to a member thereof or to such income than a cooperative bank to a member thereof or to such income than a cooperative bank to a member thereof or to such income credited or paid by a coop credited or paid by a cooperative society to any other cooperative erative society to any other cooperative society." 5.5. Reliance is also placed on the judgment of Hon'ble Karnataka 5.5. Reliance is also placed on the judgment of Hon'ble Karnataka 5.5. Reliance is also placed on the judgment of Hon'ble Karnataka High Court in the case of PCIT v. The Totagars Co High Court in the case of PCIT v. The Totagars Co-operative Sale operative Sale Society Sirsi in dated 16.06.2017. The Society Sirsi in dated 16.06.2017. The Society Sirsi in ITA No. 100066/2016 dated 16.06.2017. The relevant part o relevant part of the judgment is being reproduced below: f the judgment is being reproduced below: "13. What Section 80P(2)(d) of the Act, which was though not "13. What Section 80P(2)(d) of the Act, which was though not "13. What Section 80P(2)(d) of the Act, which was though not specifically argued and canvassed before the Hon'ble Supreme specifically argued and canvassed before the Hon'ble Supreme specifically argued and canvassed before the Hon'ble Supreme Court, envisages is that such interest or dividend earned by an Court, envisages is that such interest or dividend earned by an Court, envisages is that such interest or dividend earned by an assessee co-operative societ operative society should be out of the investments y should be out of the investments with any other co with any other co-operative society. The words 'Co operative society. The words 'Co-operative Banks' are missing in clause (d) of subsection (2) of Section 80P of Banks' are missing in clause (d) of subsection (2) of Section 80P of Banks' are missing in clause (d) of subsection (2) of Section 80P of the Act. Even: the Act. Even: though a co- - operative bank may have the corporate body or operative bank may have the corporate body or skeleton of a coo skeleton of a cooperative society but its business is entirely perative society but its business is entirely different and that is the banking business, which is governed and different and that is the banking business, which is governed and different and that is the banking business, which is governed and regulated by the provisions of the Banking Regulation Act, 1949. regulated by the provisions of the Banking Regulation Act, 1949. regulated by the provisions of the Banking Regulation Act, 1949. Only the Primary Agricultural Credit Societies with their limited Only the Primary Agricultural Credit Societies with their limited Only the Primary Agricultural Credit Societies with their limited work of provi work of providing credit facility to its members continued to be ding credit facility to its members continued to be governed by the ambit and scope of deduction under Section 80P governed by the ambit and scope of deduction under Section 80P governed by the ambit and scope of deduction under Section 80P of the Act.
14. The banking business, even though run by a Co 14. The banking business, even though run by a Co 14. The banking business, even though run by a Co- operative bank is sought to be excluded from the beneficial provisions of bank is sought to be excluded from the beneficial provisions of bank is sought to be excluded from the beneficial provisions of exemption or deduction under Section 80P of the Act. The purpose ption or deduction under Section 80P of the Act. The purpose ption or deduction under Section 80P of the Act. The purpose of bringing on the statute book sub of bringing on the statute book sub-section (4) in Section 80P of the section (4) in Section 80P of the Act was to exclude the applicability of Section 80P of the Act Act was to exclude the applicability of Section 80P of the Act Act was to exclude the applicability of Section 80P of the Act altogether to any co altogether to any co-operative bank and to exclude the normal operative bank and to exclude the normal banking business income from such exemption / deduction banking business income from such exemption / deduction banking business income from such exemption / deduction category. The words used in Section 80P(4) are significant. category. The words used in Section 80P(4) are significant. category. The words used in Section 80P(4) are significant. They are: "The provisions of this section shall not apply in relation to are: "The provisions of this section shall not apply in relation to are: "The provisions of this section shall not apply in relation to any co-operative bank other than a primary agricultural credit operative bank other than a primary agricultural credit operative bank other than a primary agricultural credit society ..... " The words "in relation to" " The words "in relation to" can include within its ambit can include within its ambit and even the interest income earned by the respondent and even the interest income earned by the respondent and even the interest income earned by the respondent-assessee, a co-operative Society from a Co operative Society from a Co-operative Bank. This exclusion by operative Bank. This exclusion by Section 80P(4) of the Act even though without any amendme Section 80P(4) of the Act even though without any amendme Section 80P(4) of the Act even though without any amendment in Section 80P(2)(d) of the Act is sufficient to deny the claim of the Section 80P(2)(d) of the Act is sufficient to deny the claim of the Section 80P(2)(d) of the Act is sufficient to deny the claim of the respondent assessee for deduction under Section 80P(2)(d) of the respondent assessee for deduction under Section 80P(2)(d) of the respondent assessee for deduction under Section 80P(2)(d) of the Act. The only exception is that of a primary agricultural credit Act. The only exception is that of a primary agricultural credit Act. The only exception is that of a primary agricultural credit society. The depository Kanara District Central Bank society. The depository Kanara District Central Bank society. The depository Kanara District Central Bank Limited in the present case is admittedly not such a primary agricultural the present case is admittedly not such a primary agricultural the present case is admittedly not such a primary agricultural credit society. credit society. 5.6.In view of the above, this Ground of appeal
is dismissed 5.6.In view of the above, this Ground of appeal is dismissed 5.6.In view of the above, this Ground of appeal is dismissed.”
3. We have heard rival submissions of the parties and perused We have heard rival submissions of the parties and perused We have heard rival submissions of the parties and perused the relevant materials on record the relevant materials on record. We find that the Hon’ble Supreme d that the Hon’ble Supreme Court in the case of Kerala State Co Kerala State Co-Operative Agricultural & Rural Operative Agricultural & Rural Development Bank Ltd. Development Bank Ltd. [2023] 154 taxmann.com 305 (SC) [2023] 154 taxmann.com 305 (SC) held that if the co-operative bank is operative bank is carrying out the business of banking the business of banking as defined u/s 5(b) of the Act B defined u/s 5(b) of the Act Banking regulation Act then only such anking regulation Act then only such co-operative bank shall be barred for deduction u/s 80P(2)(d) of the operative bank shall be barred for deduction u/s 80P(2)(d) of the operative bank shall be barred for deduction u/s 80P(2)(d) of the Act in view of prohibition u/s 80P(2)(4) of the Act Act in view of prohibition u/s 80P(2)(4) of the Act, otherwise the co otherwise the co- operative bank not falling u/s 5(b) of the Act B ot falling u/s 5(b) of the Act Banking regulation Act anking regulation Act shall be considered as co onsidered as co-operative society eligible for deduction u/s operative society eligible for deduction u/s 80P(2)(d) of the Act. The Co 80P(2)(d) of the Act. The Co-ordinate Bench of the Tribunal in the ordinate Bench of the Tribunal in the case of GSSS Credit Co case of GSSS Credit Co-operative Society Ltd. v. ITO in operative Society Ltd. v. ITO in 249 & 250/Bang/2024 held similar finding. For ready reference, 249 & 250/Bang/2024 held similar finding. For ready referen 249 & 250/Bang/2024 held similar finding. For ready referen said finding is reproduced as under: said finding is reproduced as under:
“12. Regarding the interest income earned from the Co 12. Regarding the interest income earned from the Co-operative Bank, in operative Bank, in this regard, we are of the opinion that we have to see whether the Co this regard, we are of the opinion that we have to see whether the Co this regard, we are of the opinion that we have to see whether the Co- operative Bank is carrying on the business of bank as provided ITA operative Bank is carrying on the business of bank as provided ITA operative Bank is carrying on the business of bank as provided 249 & 250/Bang/2024 under the Bank Regu No.248, 249 & 250/Bang/2024 under the Bank Regulation Act. In simple lation Act. In simple words, if the Co words, if the Co-operative Bank is not carrying out any banking business, operative Bank is not carrying out any banking business, then in our considered view, the deduction on account of interest on the then in our considered view, the deduction on account of interest on the then in our considered view, the deduction on account of interest on the investment made in such Co investment made in such Co-operative Bank cannot be denied for the operative Bank cannot be denied for the reason that such Co reason that such Co- operative Bank is not a bank as per the judgment of operative Bank is not a bank as per the judgment of Hon'ble Supreme Court in the case of Hon'ble Supreme Court in the case of Kerala State Co Kerala State Co-operative Agricultural and Rural Bank Ltd., Vs. ACIT Agricultural and Rural Bank Ltd., Vs. ACIT reported in 154 taxmann.com reported in 154 taxmann.com 305, wherein it 305, wherein it was observed that the assessee was a state was observed that the assessee was a state-level agricultural and rural development bank and governed under the agricultural and rural development bank and governed under the agricultural and rural development bank and governed under the Kerala Co-operative Societies Act, 1969 operative Societies Act, 1969 as a co-operative society. The activity of operative society. The activity of the assessee was to provide credit facilities to its members. Accordingly, see was to provide credit facilities to its members. Accordingly, see was to provide credit facilities to its members. Accordingly, the assessee claimed a deduction under the assessee claimed a deduction under Section 80P(2)(a)(i) Section 80P(2)(a)(i) of the Act in the return of income. But the AO disallowed the same on the reas the return of income. But the AO disallowed the same on the reas the return of income. But the AO disallowed the same on the reasoning that the assessee was a cooperative bank and, therefore, it was hit by the that the assessee was a cooperative bank and, therefore, it was hit by the that the assessee was a cooperative bank and, therefore, it was hit by the provisions of section 80P(4) section 80P(4) of the Act and thus would not be eligible for of the Act and thus would not be eligible for claiming deduction under claiming deduction under section 80P(2) of the Act. Finally, the issue of the Act. Finally, the issue reached the Hon'ble Apex Court where it was held that banking is defined reached the Hon'ble Apex Court where it was held that banking is defined reached the Hon'ble Apex Court where it was held that banking is defined under section 5(b) section 5(b) of the Banking Regulation Act, 1949 to mean accepting, o mean accepting, for the purpose of lending or investment, deposits of money from the public, for the purpose of lending or investment, deposits of money from the public, for the purpose of lending or investment, deposits of money from the public, repayable on demand or otherwise, and withdrawal by cheque, draft, repayable on demand or otherwise, and withdrawal by cheque, draft, repayable on demand or otherwise, and withdrawal by cheque, draft, order or otherwise. Therefore, a banking company must transact banking order or otherwise. Therefore, a banking company must transact banking order or otherwise. Therefore, a banking company must transact banking business with the publi business with the public. If a co-operative society would not transact the operative society would not transact the business of banking as defined in business of banking as defined in Section 5(b), it would not be a co , it would not be a co- operative bank within the meaning of operative bank within the meaning of section 56 of Banking Regulation Act of Banking Regulation Act and would be entitled to the benefit of deduction under and would be entitled to the benefit of deduction under Section 80P(2) Section 80P(2) of the Act. Since, the assessee society was an apex co the Act. Since, the assessee society was an apex co- operative society operative society within the meani within the meaning of Kerala State Co-Operative Agricultural Development Operative Agricultural Development Banks Act, 1984 Banks Act, 1984 (State Act, 1984) whose primary object was to provide ) whose primary object was to provide financial financial financial accommodation accommodation accommodation to to to its its its members members members ITA No.248, 249 249 249 & & & 250/Bang/2024 who 250/Bang/2024 who were all other co-operative societies and not operative societies and not members of the public, it was not a co members of the public, it was not a co-operative bank within the meaning operative bank within the meaning of section 5(b) read with read with Section 56 of Banking Regulation Act. Accordingly, of Banking Regulation Act. Accordingly, the deduction under Section 80P could not be denied to the assessee by the deduction under Section 80P could not be denied to the assessee by the deduction under Section 80P could not be denied to the assessee by invoking Section 80P(4) Section 80P(4) of the Act.
In view of the above, we hold that if the Co 13. In view of the above, we hold that if the Co-operative Bank is not rative Bank is not functioning the business of banking as defined functioning the business of banking as defined u/s 5(b) u/s 5(b) of Banking Regulation Act, then such Co Regulation Act, then such Co-operative Bank shall be considered as Co operative Bank shall be considered as Co- operative Society for the purpose of the deduct operative Society for the purpose of the deduction claimed u/s 80P(2)(d) u/s 80P(2)(d) of the Act. Therefore, in our considered view, such interest income will be the Act. Therefore, in our considered view, such interest income will be the Act. Therefore, in our considered view, such interest income will be eligible for deduction eligible for deduction u/s 80P(2)(d) of the Act.
However, if the Co 14. However, if the Co-operative Bank is carrying out banking activities as operative Bank is carrying out banking activities as defined u/s 5(b) of the Bank Regulation Act, then the assessee shall not be defined u/s 5(b) of the Bank Regulation Act, then the assessee shall not be defined u/s 5(b) of the Bank Regulation Act, then the assessee shall not be entitled for the deduction with respect to the interest earned on the entitled for the deduction with respect to the interest earned on the entitled for the deduction with respect to the interest earned on the investments made with such bank un investments made with such bank under the provisions of sec. 80P(2)(d) sec. 80P(2)(d) of the Act. However, corresponding interest cost incurred by the assessee the Act. However, corresponding interest cost incurred by the assessee the Act. However, corresponding interest cost incurred by the assessee shall be eligible to be adjusted against such interest income at par with shall be eligible to be adjusted against such interest income at par with shall be eligible to be adjusted against such interest income at par with nationalized bank. nationalized bank.” 3.1 Accordingly, the matter is restored back to the file of the Accordingly, the matter is restored back to the file of the Accordingly, the matter is restored back to the file of the Assessing Officer for verifying whether the Co Assessing Officer for verifying whether the Co-operative Banks operative Banks from whom interest is received, whom interest is received, are registered u/s 5(b) of the Banking are registered u/s 5(b) of the Banking Regulation Act or not Act or not and thereafter shall decide the is and thereafter shall decide the issue in accordance with law. The assessee may file necessary document in . The assessee may file necessary document in . The assessee may file necessary document in support of its contention contention before the Assessing officer before the Assessing officer. Accordingly, the grounds of appeal of the assessee are allowed for statistical the grounds of appeal of the assessee are allowed for statistical the grounds of appeal of the assessee are allowed for statistical purposes.
Order pronounced in the open Court on Order pronounced in the open Court on 21/01/2025. /01/2025.