INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

ITA 2347/BANG/2024Status: DisposedITAT Bangalore30 June 2025AY 2018-1944 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that interest income earned by a co-operative society from investments in co-operative banks is eligible for deduction under Section 80P(2)(d) of the Income Tax Act. It relied on the jurisdictional High Court's decision in 392 ITR 74, stating that a co-ordinate bench must follow an earlier decision of a co-ordinate bench of the same jurisdiction.

What were the facts?

The Revenue appealed against the CIT(A)'s order allowing deduction under Section 80P(2)(d) for interest income earned by a co-operative society from investments in co-operative banks. The assessee also filed cross-objections seeking further deductions.

What were the issues?

Whether interest income earned by a co-operative society from investments in co-operative banks is deductible under Section 80P(2)(d), and whether a co-ordinate bench is bound by a previous decision of a co-ordinate bench of the same jurisdiction.

Which sections of the Income-tax Act were involved?

Section 80P(2)(d),Section 80P(2)(a)(i),Section 143(1),Section 143(3),Section 250,Section 115JB(2),Section 271(1)(a)(i)

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Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Smt. Neha Sahay, D.R
For Respondent: Smt. Neha Sahay, D.R

PER BENCH: These appeals at the instances of revenue are directed against the orders of 1d. CIT(A)/NFAC dated 24.09.2024 vide DIN & Order No. ITBA/NFAC/S/250/2024-25/1069056936(1) for the assessment year 2018-19 & dated 26.9.2024 vide DIN & Order No.ITBA/NFAC/S/250/2024-25/1069106925(1) for the assess

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