INCOMETAX OFFICER, WARD-1, TIPTUR vs. SRI UDAYRAVI CREDIT CO-OP, TIPTUR

ITA 2094/BANG/2024Status: DisposedITAT Bangalore14 November 2025AY 2017-18Bench: SHRI.LAXMI PRASAD SAHU (Accountant Member), SHRI. KESHAV DUBEY (Judicial Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal dismissed the Revenue's appeal, holding that the cooperative society was eligible for the deduction under section 80P(2)(a)(i). The Tribunal noted that the nominal members were minimal and the society's objectives aligned with the spirit of cooperative principles.

What were the facts?

The Revenue appealed against the CIT(A)'s order allowing deduction under section 80P(2)(a)(i) to a cooperative society registered under the Karnataka State Souharda Sahakari Act, 1997. The Revenue argued that the society violated membership restrictions for nominal members and thus was not eligible for the deduction.

What were the issues?

Whether a cooperative society registered under the Karnataka State Souharda Sahakari Act, 1997, with nominal members, is eligible for deduction under Section 80P(2)(a)(i) of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 80P,Section 69A,Section 115BBE

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Income Tax Appellate Tribunal, “B” BENCH : BANGALORE

Before: SHRI.LAXMI PRASAD SAHU & SHRI. KESHAV DUBEY

For Appellant: Smt. Harsha J, Advocate
For Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Hearing: 30.10.2025Pronounced: 14.11.2025

Per Laxmi Prasad Sahu, Accountant Member :

These two appeals are filed by the Revenue against separate Orders passed by the CIT(A) for Assessment Years 2017-18, 2018-19vide DIN and Order No.ITBA/NFAC/S/250/2024-25/1067460218(1) and No.ITBA/NFAC/S/250/2024-25/1067460540(1) dated 08.08.2024 respectively.

2.

The grounds raised by the Revenue are as follows:

1.

The decision of CIT(A)/ NFAC is opposed to facts of the case in allowing the entire deduction u/s 80P(2)(a)(i) of the Act.

2.

As per section 2(24)(viia)- Profits and Gains of any business of banking(including providing credit facilities) carried on by a Co-operative soci

The order continues below.

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