SURENDRANAGAR DISTRICT CO OP PRODUCERS UNION LIMITED,SURENDRANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, SURENDRANAGAR CIRCLE

ITA 429/RJT/2025Status: DisposedITAT Rajkot10 February 2026AY 2014-15Bench: DR. ARJUN LAL SAINI (Accountant Member), DR. DINESH MOHAN SINHA (Judicial Member)25 pages
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What did the Tribunal hold?

The Tribunal held that the assessee, by collecting milk from farmers and supplying it to a federal cooperative society, functions as a primary cooperative society and is eligible for deduction under Section 80P(2)(b). It also held that interest and dividend income derived from investments with other cooperative societies are deductible under Section 80P(2)(d).

What were the facts?

The assessee, a district-level cooperative society engaged in milk procurement and distribution, claimed deductions under Section 80P(2)(b) and Section 80P(2)(d) of the Income Tax Act. The Assessing Officer and CIT(A) disallowed these deductions, holding that the assessee was not a primary society eligible for 80P(2)(b) and that interest and dividend income were not deductible under 80P(2)(d).

What were the issues?

Whether a district-level cooperative society collecting milk from farmers is eligible for deduction under Section 80P(2)(b), and whether interest and dividend income from other cooperative societies are deductible under Section 80P(2)(d).

Which sections of the Income-tax Act were involved?

Section 80P(2)(b),Section 80P(2)(d),Section 143(3),Section 250,Section 271(1)(c),Section 234A,Section 234B,Section 234C

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Income Tax Appellate Tribunal, RAJKOT BENCH, RAJKOT

Before: DR. ARJUN LAL SAINI & DR. DINESH MOHAN SINHA

For Appellant: Shri Kalpesh Doshi, Ld. AR
For Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Per, Dr. Arjun Lal Saini, A.M.:

Captioned appeal filed by the assessee, pertaining to Assessment Year 2014- 15, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 28.04.2025, which in Surendranagar Dist. Co-op. Milk Producer turn arises out of

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