BELLARE C A BANK LTD. ,BELLARE vs. INCOME TAX OFFICER, WARD-1, , PUTTUR
What did the Tribunal hold?
The ITAT held that interest income from investments in banks, even if made under compulsion, is not attributable to the main business of providing credit facilities and thus not deductible under Section 80P(2)(a)(i). The issue of deduction under Section 80P(2)(d) for interest from co-operative banks was remitted to the AO for verification.
What were the facts?
The assessee, a primary agricultural co-operative society, claimed deduction under Section 80P on its income. The AO denied the deduction, treating investment income as 'income from other sources' and disallowed provision for NPA. The CIT(A) allowed partial deduction under Section 80P(2)(a)(i) and Section 57.
What were the issues?
Whether interest income from investments in banks is deductible under Section 80P(2)(a)(i) and whether interest income from co-operative banks is deductible under Section 80P(2)(d).
Which sections of the Income-tax Act were involved?
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Cases cited in this judgment(7)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Pr. CIT v. Totagars1,074 citing395 ITR 611 · 2017 · HC
- Citizen Co-operative Society Ltd. v. ACIT499 citing397 ITR 1 · 2017 · SC
- Totgar's Co-operative Sale Society Ltd. v. ITO486 citing188 Taxmann 282 · 2010 · SC
- Kerala State Co-operative Agricultural and Rural Development Bank Ltd. v. Assessing Officer136 citing154 Taxmann.com 305 · 2023 · SC · Read judgment
- New Noble Educational Society v. CIT52 citing143 Taxmann.com 276 · 2022 · SC · Read judgment
- Mavilayi Service Cooperative Bank Ltd., & Ors. v. Commissioner of Income Tax, Calicut & Anr.23 citing123 Taxmann.com 1 · 2021 · SC · Read judgment
- New Noble Educational Society v. Chief CIT14 citing290 Taxmann 206 · 2023
Income Tax Appellate Tribunal, B BENCH : BANGALORE
Before: SHRI LAXMI PRASAD SAHU & SHRI KESHAV DUBEY
Per Laxmi Prasad Sahu, Accountant Member This appeal is filed by the assessee against the order dated 20.12.2023 of the CIT(Appeals), National Faceless Appeal Centre, Delhi [NFAC], for the AY 2017-18 on the following revised grounds dated 21.5.2024 :- “1. The learned CIT (A) appeal erred in passing the orders in the manner he did.
The learned CIT(A) appeal erred restricting the deduction under 80P(2)(a)(i) to the extent of Rs.11,99,658/- as against Rs.48,97,193/- without appreciating the submission of the appellant.
The learned CIT(A) erred in restricting the deduction under 57 to the extent of Rs.24,59,246/- as against Rs.66,16,858
The order continues below.
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More judgments on Section 80P
- Shree Bandharda Seva Sahkari Mandli Ltd… vs Income Tax Officer Ward -4, JunagadhITA 881/RJT/2025[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Duddukuru Primary Agricultural Cooperative… vs ITO, Ward - 1, TadepalligudemITA 258/VIZ/2026[2015-16]Status: Disposed16 Oct 2026AY 2015-16
- Parthasaradhi Mutually Aided Co-Operative… vs Income-Tax Officer, Ward-17(1), HyderabadITA 2322/HYD/2026[AY 2016-17]Status: Disposed16 Oct 2026
- Jijamata Mahila Gramin Bigar Sheti Sahakari… vs ITO Ward -1, BhandraITA 102/NAG/2026[2020-21]Status: Disposed12 Oct 2026AY 2020-21
- Shri Na vs Ari Khedut Sahkari Society Ltd…ITA 362/SRT/2025[2016-17]Status: Disposed9 Oct 2026AY 2016-17
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