GONIKOPPAL PRIMARY RURAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-3, BENGALURU

ITA 1072/BANG/2025Status: DisposedITAT Bangalore03 December 2025AY 2020-21Bench: SHRI PRASHANT MAHARISHI (Vice President), SHRI KESHAV DUBEY (Judicial Member)31 pages
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What did the Tribunal hold?

The Tribunal held that the assessment order was neither erroneous nor prejudicial to the interest of the revenue. Following Supreme Court and High Court precedents, the Tribunal found that the AO's view was plausible and not unsustainable in law.

What were the facts?

The assessee, a co-operative society, claimed deduction under Section 80P(2)(a)(i) for interest income earned from co-operative and commercial banks. The Principal CIT initiated proceedings under Section 263, considering the AO's order erroneous and prejudicial to revenue, citing the Totagars Co-operative Sale Society case.

What were the issues?

Whether the Principal CIT was justified in invoking Section 263 to revise an assessment order where the AO had allowed deduction under Section 80P on interest income earned from banks, considering the possibility of two views.

Which sections of the Income-tax Act were involved?

Section 80P,Section 263,Section 56

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Income Tax Appellate Tribunal, “A’’BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

Hearing: 10.09.2025Pronounced: 03.12.2025

PER KESHAV DUBEY, JUDICIAL MEMBER:

The appeal in ITA No.1074/Bang/2025 at the instance of the assessee is directed against the order of the ld. PCIT, Hubli dated M/s. Bhavana Co op Credit Society Niyamitha, Sirsi 25.03.2025 vide DIN & Order No. ITBA/REV/F/REV5/2024- 25/1075012813(1) and the appeal in ITA No.1072/Bang/2025 is directed against the order of the ld. PCIT, Bengaluru-3 dated 24.3.2025 vide DIN

The order continues below.

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