SHRI BHAIRAVNATH MULTI STATE CO-OP CREDIT SOCIETY LIMITED,SATARA vs. INCOME TAX OFFICER, WARD 3, SATARA

IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCHES “B”, PUNE

BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER
AND SHRI VINAY BHAMORE, JUDICIAL MEMBER

आयकर अपील सं. / ITA No.2576/PUN/2025
Assessment Year : 2020-21

Shri Bhairavnath Multi State
Co.op. Credit Society Limited,
48, Deccan Chowk,
Laxmi Nagar, Phaltan,
Satara – 415 523
Maharashtra
PAN : AAEAS8344J
Vs.
The Income Tax Officer,
Ward-3, Satara
Appellant

Respondent

आदेश / ORDER

PER DR. MANISH BOARD, ACCOUNTANT MEMBER :

The captioned appeal at the instance of assessee pertaining to A.Y. 2020-21 is directed against the order dated
27.10.2025 framed by National Faceless Appeal Centre, Delhi arising out of Assessment Order dated 19.09.2022 passed u/s.143(3) r.w.s.144B of the Income Tax Act, 1961. 2. The only grievance of the assessee is that ld.CIT(A) erred in affirming the action of the AO of not granting deduction u/s.80P(2)(d) of the Act for the interest income earned on investments held with Cooperative
Banks/Cooperative
Societies.

Appellant by :
Shri Prayag Jha and Shri Prateek Jha
Respondent by :
Shri Pramod Shahkar
Date of hearing
:
10.12.2025
Date of pronouncement
:
18.12.2025
Shri Bhairavnath Multi State
Coop. Credit Society Ltd.

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3. At the outset, ld. Counsel for the assessee submitted that there is no dispute about the fact that assessee earned interest of ₹3,87,34,866 from investments held with Cooperative Banks and this fact is clearly discernible from the assessment order.
He submitted that in assessee’s own case for A.Y. 2014-15
similar issue has been decided in favour of the assessee and deduction u/s.80P(2)(d) of the Act has been allowed. He further submitted that a consistent view has been taken by this Tribunal allowing the deduction u/s.80P(2)(d) of the Act for the interest income earned from investments held with Cooperative Banks as well as Cooperative Societies.

“5. We have heard the rival submissions and perused the record placed before us. There is no dispute to the fact that assessee has earned interest income of Rs.1,02,95,103/- from deposits/investments with Cooperative Banks. This fact has been accepted by the Assessing Officer in the assessment order also.
Admittedly, assessee has not filed the requisite details before ld.CIT(A). We however considering the fact that the issue regarding allowability of deduction u/s.80P(2)(d) of the Act for the interest earned from Cooperative Banks is no longer res integra as the very same issue has been decided by this Tribunal in catena of decisions
Shri Bhairavnath Multi State
Coop. Credit Society Ltd.

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and in assesse’s own case for A.Y. 2020-21 holding that the assessee is eligible for deduction u/s.80P(2)(d) of the Act as the Cooperative Banks are basically Cooperative Societies. For the sake of brevity, the finding given in ITA No.2471/PUN/2024 is reproduced below:

“7. We have heard both the sides and perused the record placed before us. In the instant case, the Assessing Officer disallowed the interest income of Rs.1,63,98,998/- earned out of the Fixed deposits/Investments made with Cooperative
Banks treating the same as Income from Other Source.
Ld.CIT(A) dismissed the appeal in limine without discussing anything on merits of the issues and on the ground that the assessee has not provided plausible explanation for admission of additional evidences.

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merits is set aside and grounds of appeal No.5 to 8 raised by the assessee are allowed.”

Order pronounced on this 18th day of December, 2025. (VINAY BHAMORE)
ACCOUNTANT MEMBER

पुणे / Pune;
दनांक / Dated : 18th December, 2025. Satish

आदेश क ितिलिप अ ेिषत / Copy of the Order forwarded to :

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