INCOME TAX OFFICER, WARD-20(3)(1), MUMBAI, MUMBAI vs. THE CENTRAL RAILWAY EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD, MUMBAI

PDF · subscribers
ITA 6894/MUM/2025Status: DisposedITAT Mumbai06 March 2026AY 2023-24Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI JAGADISH (Accountant Member)1 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee, a cooperative credit society engaged in providing credit facilities to its members, is eligible for deduction under section 80P(2)(a)(i). This was based on a previous decision of a co-ordinate bench in the assessee's own case for earlier assessment years.

What were the facts?

The Revenue filed appeals against the CIT(A)'s orders allowing deduction under section 80P(2)(a)(i) for AYs 2022-23 and 2023-24. The issues were identical for both years and the CIT(A) had passed identical orders. The assessee is a cooperative credit society.

What were the issues?

Whether the assessee, a cooperative credit society, is eligible for deduction under section 80P(2)(a)(i) of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI JAGADISH

For Appellant: Shri Fenil Bhatt, Adv
For Respondent: Shri Virabhadra Mahajan, (SR. DR.)
Hearing: 05.03.2026Pronounced: 06.03.2026

ORDER Per: SHRI JAGADISH, A.M.:

1.

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.

3.

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.

4.

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.

More judgments on Section 80P(2)(a)(i)

All 2,347 judgments and leading authorities on Section 80P(2)(a)(i) →

Recent GST High Court judgments

Search GST case law →