SIDDHARATHA PATTINA SAHAKARI SANGHA NIYAMITA,BELLARY vs. INCOME TAX OFFICER, WARD-1 & TPS, HOSPET

ITA 2113/BANG/2024Status: DisposedITAT Bangalore29 May 2025AY 2017-18Bench: SHRI WASEEM AHMED (Accountant Member), SHRI SOUNDARARAJAN K (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the E-stamping commission from non-members was a minor fraction of the total income and did not disentitle the assessee from the deduction. It further held that interest income from deposits made to meet statutory requirements was operational income and eligible for deduction.

What were the facts?

The assessee, a cooperative society, claimed deduction under Section 80P(2)(a)(i) on its net profit which included interest income from deposits with a cooperative bank and commission from E-Stamps. The AO disallowed the entire deduction due to transactions with non-members and interest from deposits.

What were the issues?

Whether income from E-stamping commission from non-members and interest from statutory deposits are eligible for deduction under Section 80P despite the principle of mutuality.

Which sections of the Income-tax Act were involved?

Section 80P,Section 80P(2)(a)(i),Section 80P(2)(d)

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Income Tax Appellate Tribunal, ‘A’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K

For Appellant: Shri Varun Bhat, CA
For Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Hearing: 07.04.2025Pronounced: 29.05.2025

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is an appeal filed by the assessee against the order passed by the Addl/JCIT(A)-2, Noida dated 04/10/2024 in DIN No. ITBA/ NFAC/ S/250/2024-25/106938591(1) for the assessment year 2017-18. 2. The assessee has raised as many as 5 grounds of appeal, however the issue raised in ground Nos. 1 to 5 are interconnected and pertain to disallowances of deduction claimed under section 80P(2)(a)(i) of the Act.

3.

The facts in brief are that the assessee is a cooperative society registered under the Karnataka Co-operative Societies Act (here after the KCSA) engaged in the business of providing credit facil

The order continues below.

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