THE BRAHMALING MULTIPURPOSE CO-OP SOCIETY LTD,BELGAUM vs. INCOME TAX OFFICER, WARD -3, BELGAUM

ITA 254/PAN/2025Status: DisposedITAT Panaji22 December 2025AY 2017-18Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)17 pages
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What did the Tribunal hold?

The Tribunal restored the issue of deduction for dealings with nominal/associate members and interest income from scheduled banks to the Assessing Officer for fresh adjudication. It directed that the deduction for interest income from cooperative banks/societies be allowed as per Section 80P(2)(d).

What were the facts?

The assessee, a cooperative credit society, claimed deduction under Section 80P(2)(a)(i) for income related to dealings with associate/nominal members and interest income from deposits. The Assessing Officer and CIT(A) denied this deduction, leading to the present appeal.

What were the issues?

Whether the cooperative society is eligible for deduction under Section 80P(2)(a)(i) for dealings with associate/nominal members and interest income from scheduled banks, and whether interest income from cooperative banks is deductible under Section 80P(2)(d).

Which sections of the Income-tax Act were involved?

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

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Income Tax Appellate Tribunal, “SMC” BENCH PANAJI

Before: SHRI PAVAN KUMAR GADALE

Hearing: 16.12.2025Pronounced: 22.12.2025

PER PAVAN KUMAR GADALE, JM:

The appeal is filed by the assesse against the order of ADDL/JCIT (A)-2 surat passed u/sec 143(3) and u/sec 250 of the Act. The assessee has raised the grounds of appeal challenging the order of the CIT(A) sustaining the denial of claim of deduction u/sec80P(2)(a)(i) of the Act made by the Assessing Officer in respect of dealings with the Associate/Nominal members and without prejudice alternate reliefs u/sec80P(2)(d) of the Act.

2.

The brief facts of the case are that, the assessee is a cooperative credit society and is engaged in activities of providing credit facilities to its members

The order continues below.

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