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Facts
The assessee, a credit co-operative society, appealed against the Income Tax Appellate Tribunal's order for AY 2018-19, which denied deductions under Section 80P(2)(a)(i) and Section 80P(2)(d) for interest income earned from deposits in KDCC Bank. The assessee sought to set aside the Tribunal's order.
Held
The High Court noted that the substantial questions of law raised in the appeal were covered by its previous decision in ITA No.118/2025. Consequently, the present appeal was disposed of in terms of the order passed in the said precedent case.
Key Issues
Whether the assessee is entitled to claim deduction under Section 80P(2)(a)(i) for interest income from deposits in KDCC Bank, and alternatively, whether deduction under Section 80P(2)(d) is applicable.
Sections Cited
Section 260-A, Section 80P(2)(a)(i), Section 80P(2)(d)
AI-generated summary — verify with the full judgment below
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HC-KAR NC: 2026:KHC:6224-DB ITA No. 94 of 2025
IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 3RD DAY OF FEBRUARY, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND INCOME TAX APPEAL NO.94 OF 2025 BETWEEN:
SRI. LAXMINARAYANA SUVARNA CREDIT CO-OPERATIVE SOCIETY LTD., NO.152/1, SIDDAPURA-581355, UTTARA KANNADA DISTRICT. BY ITS CHIEF EXECUTIVE OFFICER: SRI. SANDESH V. SHET …APPELLANT (BY SRI. MAHESH.R.UPPIN, ADVOCATE) AND:
THE COMMISSIONER OF INCOME TAX (APPEALS), NATIONAL FACELESS APPEAL CENTRE, DELHI - 110001.
THE INCOME TAX OFFICER, WARD - 1, SIRSI - 581401 UTTARAKANNADA DISTRICT. …RESPONDENTS (BY SRI. SUSHAL TIWARI.N., STANDING COUNSEL)
THIS ITA/INCOME TAX APPEAL IS FILED UNDER SEC. 260-A OF INCOME TAX ACT 1961, PRAYING TO SET ASIDE THE ORDER PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, BENGALURU IN ITA NO.122/BANG/2024 DATED 7.05.2024 FOR THE ASSESSMENT YEAR 2018-19 AND ETC.
Digitally signed by VINUTHA B S Location: High Court of Karnataka
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HC-KAR NC: 2026:KHC:6224-DB ITA No. 94 of 2025
THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and HON'BLE MR. JUSTICE K. V. ARAVIND
ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE K. V. ARAVIND)
This appeal is filed by the assessee assailing the order dated 07.05.2024 passed in ITA No.122/Bang/2024 by the Income Tax Appellate Tribunal, Bengaluru, (for short “the Tribunal”) relating to the Assessment Year 2018–19.
In the appeal, the following substantial questions of law has been raised: (i) In the facts and circumstances of the case, whether the Tribunal is right in holding that, the Appellant/Assessee is not entitled to claim benefit of deduction under Section 80P(2)(a)(i) in respect of interest income earned from the deposits made in KDCC Bank;
(ii) Alternatively in the facts and circumstances of the case, whether the Tribunal was right in denying benefit of deduction under Section 80P(2)(d) of the Act.
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HC-KAR NC: 2026:KHC:6224-DB ITA No. 94 of 2025
Sri Mahesh R. Uppin, learned counsel appearing for the appellant, at the outset submits that the substantial questions of law raised in the appeal are covered by the decision of this Court in ITA No.118/2025.
Sri Sushal Tiwari N., learned counsel appearing for the respondents, is not in a position to dispute the above submission.
As the substantial questions of law raised in the present appeal have already been considered and answered in ITA No.118/2025, the present appeal is disposed of in terms of the order passed in ITA No.118/2025.
Sd/- (S.G.PANDIT) JUDGE
Sd/- (K. V. ARAVIND) JUDGE
SMJ List No.: 1 Sl No.: 14