SYNDICATE RYTHARA SEVA SAHAKARA SANGHA NIYAMITHA,BANGALORE vs. DCIT, CIRCLE-4(3)(1), BANGALORE

ITA 2293/BANG/2024Status: DisposedITAT Bangalore28 August 2025AY 2018-19Bench: SHRI LAXMI PRASAD SAHU (Accountant Member), SHRI SOUNDARARAJAN K. (Judicial Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that interest income earned from co-operative banks registered under the Karnataka Co-operative Societies Act is eligible for deduction under Section 80P(2)(a)(i). The issue regarding interest income from scheduled banks was set aside and remitted to the AO for de novo consideration, with directions to allow deduction under Section 80P(2)(a)(i) if the deposits were mandatory, or tax under Section 56 with eligible deductions otherwise.

What were the facts?

The assessee, a co-operative society, claimed deduction under Section 80P for interest income earned from investments in co-operative banks and scheduled banks. The Assessing Officer (AO) disallowed the entire claim, treating the interest as income from other sources.

What were the issues?

Whether interest income earned by a co-operative society from investments in co-operative banks and scheduled banks is eligible for deduction under Section 80P, and the taxability of such income when deposits are made under statutory provisions.

Which sections of the Income-tax Act were involved?

Section 80P,Section 80P(2)(a)(i),Section 80P(2)(d),Section 56,Section 57,Section 143(2),Section 142(1),Section 80(P)(2)(a)(i)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH : BANGALORE

Before: SHRI LAXMI PRASAD SAHU & SHRI SOUNDARARAJAN K.

For Appellant: Shri Sandeep Chalapathy, CA
For Respondent: Shri Kiran D, CIT-DR

PER SOUNDARARAJAN K., JUDICIAL MEMBER

These are the appeals filed by the assessee challenging the order of the NFAC, Delhi both dated 30/09/2024 in respect of the A.Ys. 2018-19 and 2020-21. 2. Both these appeals are related to the same assessee and the issue involved in both the appeals are similar and therefore we decided to take up both the appeals together and pass a common order for the sake of convenience. ITA Nos. 2293 & 2294/Bang/2024

3.

We will take up the appeal in ITA No. 2293/Bang/2024 for A.Y. 2018- 19 as the lead case and the result arrived in the said appeal will apply mutatis

The order continues below.

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