SHREE VEGAM URBAN CO OP CREDIT SOCIETY LIMITED ,SURAT vs. ACIT, CIRCLE-1(2), SURAT

ITA 252/SRT/2025Status: HeardITAT Surat22 January 2026AY 2017-18Bench: DR. B.R.R. KUMAR, VICE-PRESIDENT MS SUCHITRA RAGHUNATH KAMBLE (Judicial Member)5 pages
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What did the Tribunal hold?

The Tribunal held that interest earned by a co-operative society from investments made in co-operative banks is eligible for deduction under section 80P(2)(d) of the Income-tax Act. This is based on the understanding that co-operative banks are considered co-operative societies for the purpose of this deduction, and the exclusion under section 80P(4) does not affect this eligibility when the co-operative bank itself is not liable to pay tax.

What were the facts?

The assessee, a co-operative society, claimed deduction under section 80P(2)(d) for interest income earned from fixed deposits in co-operative banks. The Assessing Officer made an addition for this interest income and dividend income. The assessee appealed to the CIT(A) against this addition.

What were the issues?

Whether interest income received by a co-operative society from co-operative banks is eligible for deduction under Section 80P(2)(d) and if Section 80P(4) excludes such deduction.

Which sections of the Income-tax Act were involved?

Section 80P,Section 80P(2)(d),Section 80P(4)

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Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: DR. B.R.R. KUMAR, VICE-MS SUCHITRA RAGHUNATH KAMBLE

For Appellant: Shri Shaunak K. Zaveri, CA
For Respondent: Ms Namita Patel, Sr. DR
Hearing: 19.01.2026Pronounced: 22.01.2026

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:

This appeal has been filed by the assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, [hereinafter referred to as “Ld. CIT(A)”] dated 21.11.2024, under section 250 of the Income-tax Act, 1961 [in short “the Act”] for the Assessment Year 2013-14. 2. The solitary issue required to be adjudicated by this Tribunal is that whether the assessee is eligible for deduction u/s 80P(2)(d) of the Act, for the interest received from the Co-operative Banks. In this case, an addition has been made by the Assessing Officer on account of interest

The order continues below.

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