GMEDAPADU PACS,GMEDAPADU vs. ITO, WARD-1, KAKINADA

ITA 574/VIZ/2025Status: DisposedITAT Visakhapatnam19 November 2025AY 2020-21Bench: Shri Manjunatha G. (Accountant Member), Shri Ravish Sood (Judicial Member)19 pages
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What did the Tribunal hold?

The Tribunal held that commission income from the State Civil Supplies Corporation is not eligible for deduction under Section 80P as it arises from a transaction with a non-member. However, interest income earned from deposits with a cooperative bank is eligible for deduction under Section 80P(2)(d).

What were the facts?

The assessee, a primary agricultural co-operative society, claimed deduction under Section 80P for interest income from a cooperative bank and commission earned from the State Civil Supplies Corporation. The Assessing Officer disallowed both claims, viewing the commission as from a non-member and the interest as ineligible for deduction.

What were the issues?

Whether commission income from a government agency is eligible for deduction under Section 80P, and whether interest income from a cooperative bank is eligible for deduction under Section 80P(2)(d).

Which sections of the Income-tax Act were involved?

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

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Income Tax Appellate Tribunal, Visakhapatnam, “DIVN” Bench, Visakhapatnam

Before: Shri Manjunatha G. & Shri Ravish Sood

PER. RAVISH SOOD, J.M:

The present appeal filed by the assessee society is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 30.07.2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under Section 143(3) of the Income-tax Act, 1961 (for short, “Act”), for 2 the Assessment Year 2020–21. The assessee society has assailed the impugned order on the following grounds of appeal before us:

“1. The order of the Hon CIT(A) is arbitrary and unjustice

The order continues below.

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