VRIHTAKAR SEVA SAHAKARI SAMITI MARYADIT SURGI,RAJNANDGAON vs. INCOME TAX OFFICER-1, RAJNANDGAON, RAJNANDGAON

ITA 105/RPR/2026Status: DisposedITAT Raipur26 February 2026AY 2018-19Bench: SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)9 pages
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What did the Tribunal hold?

The Tribunal held that interest income earned by a cooperative credit society from bank deposits is attributable to its business of providing credit facilities and is therefore eligible for deduction under Section 80P(2)(a)(i) and 80P(2)(d). The assessee is not considered a 'bank' for the purposes of Section 80P(4).

What were the facts?

The assessee, a cooperative society, earned interest on bank deposits. The society claimed this interest income as deductible under Section 80P(2)(a)(i) of the Income Tax Act, arguing it was part of its business activities. The Assessing Officer and CIT(Appeals) denied this deduction.

What were the issues?

Whether interest income earned by a cooperative credit society on bank deposits is eligible for deduction under Section 80P of the Income Tax Act.

Which sections of the Income-tax Act were involved?

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

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Income Tax Appellate Tribunal, RAIPUR BENCH “SMC”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Rakesh Dhody, CA
For Respondent: Dr. Priyanka Patel, Sr. DR
Hearing: 26.02.2026Pronounced: 26.02.2026

PER PARTHA SARATHI CHAUDHURY, JM The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 19.12.2025 for the assessment year 2018-19 as per the following grounds of appeal:

“1. The learned Commissioner of Income Tax (Appeals) erred in law and on facts in confirming the addition of Rs.24,70,630/- by denying deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961. 2. That the Ld. CIT(

The order continues below.

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