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Facts
The Revenue filed two appeals against the CIT(A)'s orders allowing deductions to the assessee, a cooperative credit society, under Section 80P(2)(a)(i) of the Income Tax Act for assessment years 2022-23 and 2023-24. The core issue revolves around the assessee's eligibility for this deduction.
Held
The Tribunal noted that a coordinate bench in the assessee's own case for prior assessment years had already held the assessee eligible for the deduction as a cooperative credit society providing credit facilities to its members. The Revenue presented no new material to suggest different facts for the current assessment years.
Key Issues
Whether the assessee, a cooperative credit society, is eligible for deduction under Section 80P(2)(a)(i) for the assessment years 2022-23 and 2023-24.
Sections Cited
80P(2)(a)(i)
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Income Tax Appellate Tribunal, “C” BENCH, MUMBAI
Before: SHRI SANDEEP GOSAIN & SHRI JAGADISH
ORDER Per: SHRI JAGADISH, A.M.:
These two appeals filed by the Revenue are directed against the orders of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, both dated 13.08.2025 for A.Ys. 2022–23 and 2023–24. Since identical issues are involved and the learned CIT(A) has passed identical orders, both the appeals were heard together and are disposed of by this consolidated order for the sake of convenience.
& 6894/M/2025 The Central Railway Employees Co-operative Credit Society Ltd 2. The only issue involved in both the appeals is with regard to the action of the learned CIT(A) in allowing the deduction claimed by the assessee under section 80P(2)(a)(i) of the Income Tax Act, 1961.
At the outset, the learned Authorised Representative submitted that the issue involved in the present appeals is squarely covered in favour of the assessee by the order of the co-ordinate bench of the Tribunal in the assessee’s own case in 2693 & 2783/Mum/2024 dated 11.11.2024, wherein the Tribunal has adjudicated this issue and held that the assessee is eligible for deduction under section 80P(2)(a)(i) of the Act. The learned AR submitted that the facts for the years under consideration are identical and there is no change in the nature of activities of the assessee.
On the other hand, the learned Departmental Representative relied upon the orders of the Assessing Officer and the grounds raised
in the appeals.
5. We have heard the rival submissions and perused the material available on record. We find that the learned CIT(A) allowed the claim of deduction under section 80P(2)(a)(i) following the decision of the Tribunal in the assessee’s own case for earlier assessment years. It is an admitted position that the co-ordinate bench of the Tribunal in the assessee’s own case in 2693 & 2783/Mum/2024 dated 11.11.2024 has held that the assessee is a co-operative credit society engaged in providing credit facilities to its members and therefore eligible for deduction under section 80P(2)(a)(i) of the Act. The Revenue has not brought on record any material to demonstrate that the facts for the years under consideration are different from those considered by the Tribunal in earlier years.
& 6894/M/2025 The Central Railway Employees Co-operative Credit Society Ltd 6. Respectfully following the decision of the co-ordinate bench of the Tribunal in the assessee’s own case (supra), we find no infirmity in the order of the learned CIT(A) in allowing the deduction under section 80P(2)(a)(i) of the Act. Accordingly, the grounds raised by the Revenue in both the appeals are dismissed.
7. In the result, the appeals filed by the Revenue for A.Ys. 2022–23 and 2023–24 are dismissed. Order pronounced in the open court on 06/03/2026.