THE GUNDUGOLANU LARGE SIZE COOPERATIVE SOCIETY LTD,ELURU vs. ADDL/JOINT/DCIT/ INCOME TAX OFFICER, ELURU

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ITA 313/VIZ/2025Status: DisposedITAT Visakhapatnam29 August 2025AY 2022-2310 pages
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What did the Tribunal hold?

The Tribunal, following its earlier decision in 'The Chebrole Large Sized Co-operative Society Limited Vs. ITO', held that interest income derived by a primary agricultural co-operative society from fixed deposits in nationalized banks, made from its own surplus funds, is eligible for deduction under Section 80P(2)(a)(i) of the Act. Consequently, the disallowance made by the A.O. for Rs. 16,88,240/- was directed to be vacated.

What were the facts?

The assessee, a Co-operative Society, filed its return of income for A.Y. 2022-23 declaring Rs. Nil income. The A.O. observed that the society earned interest of Rs. 16,88,240/- from investments/deposits with nationalized banks (DCCB Bank and Union Bank). The A.O. treated this interest income as 'income from other sources' and denied deduction under Section 80P, a decision upheld by the CIT(A).

What were the issues?

Whether interest income earned by a co-operative society from deposits with nationalized banks is eligible for deduction under Section 80P of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 80P,Section 80P(2)(d),Section 80P(2)(a),Section 80P(2)(a)(i)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Visakhapatnam Bench

For Appellant: Dr. Aparna Villuri, Sr.DR

आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:- 1. निर्धाररती/The Assessee : The Gundugolanu Large Size Cooperative Society Ltd., Gundugolanu, Eluru District, A.P. 2. रधजस्व/ The Revenue : The Income Tax Officer, Eluru 3. The Principal Commissioner of Income Tax, Visakhapatnam. 4. नवभधगीयप्रनतनिनर्, आयकर अपीलीय अनर्करण, / DR, ITAT, Visakhapatnam. गधर्ाफ़धईल / Guard file 5.

आदेशधिुसधर / BY ORDER

Sr. Private Secretary ITAT, Visakhapatnam

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