447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd. v. ITO Ward 2(2), Mysore

377 ITR 464High Court2015#899 most cited

What is 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd. v. ITO Ward 2(2), Mysore authority for?

Interest income earned by a credit co-operative society from temporary bank deposits, which cannot be immediately lent to members, is considered business income attributable to its credit facilities and is eligible for deduction under Section 80P(2)(a)(i). This interpretation gives a broader meaning to income 'attributable to' the business.

118

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2026.

Also referred to as

Guttigedarara Credit Co-operative Society Ltd. · 377 ITR 464 · Section 80P(2)(a)(i) · Section 80P · Section 56 · credit co-operative society · interest income from bank deposits · business income · deduction · attributable to business

Sections most often in play

Section 80P(2)(a)(i)Section 80P(2)(d)Section 143(3)Section 250Section 80PSection 263Section 2(19)Section 80P(4)

Issues it is cited on

section 57(i)section 80(p)(2)(a)section 80(2)(d)section 286section 161section 80p(2)(c)section 80p(2)(a)(iii)section 60section 80p(2)(i)section 194a(3)(v)interest on securitiessection 2(19)

Judgments citing 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd. v. ITO Ward 2(2), Mysore

Samarth Urban Co-Operative Credit Society Ltd, Belgaum vs. Pr. Commissioner of Income Tax, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 152/PAN/2024[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Samarth Urban Co-Operative Credit Society Ltd, Belgaum vs. Pr Commissioner of Income Tax, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 151/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Shri Shradha Credit Souhard Sahakari Niymit Nipani, Nipani vs. ITO, Ward-2 Belgaum, Belgaum

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 144/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Shivagiri Co-Op Credit Society Ltd, Belagavi vs. Income Tax Officer, Ward - 1(3), Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 138/PAN/2024[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Shree Mahila Credit Souhard Sahakari Sangh Niyamit, Belagavi vs. ITO Ward 1 Belagavi, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 117/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 161/PAN/2023[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 160/PAN/2023[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 159/PAN/2023[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 158/PAN/2023[2014-15]Status: DisposedITAT Panaji28 Nov 2025AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…mited & others. 2. Cambay Electric Supply Industrial Co. Ltd v CIT 113 ITR 84 (SC). 2.1 Tumkur Merchants Souharda Credit Cooperative Ltd v ITO Ward – V, Tumkur 55 taxmann.com 447 (Kar). 3. Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT v Gunja Samabay Krishi Unnayan Samiti Ltd 147 taxmann.com 518(Cal) 7. Chennai Central Co-operative Bank Ltd 148 taxmann.com 17 (Mad). 8. Athani…

Southern Railway Employees Cooperative Credit Society Ltd., Tiruchirapalli vs. DCIT, Cirlce-1(1), Trichy

In the result, the appeal filed by the assessee is allowed

ITA 2478/CHNY/2024[2018-19]Status: DisposedITAT Chennai16 Jul 2025AY 2018-19

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI JAGADISH (Accountant Member)

For Appellant: Shri P.M.Kathir, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…its members. Thus, the assessee society is entitled to special deduction under section 80P(2)(a)(i) of the Act. Our view is duly fortified by the decision of the Hon’ble Karnataka High Court in the case of Guttigedarara Credit Cooperative Society Ltd. v. ITO 377 ITR 464, wherein, the Hon’ble Karnataka High Court has observed and held as under: “7. From the aforesaid facts and rival contentions, the undisputed facts which emerge are, certain sums of interest were earned from short-term deposits and from savings bank account. The assessee is a Co-operative Society providing credit facilities to its members. It is…

The DCIT, Cir-3(2) Gangtok, Gangtok Sikkim vs. Sikkim State Cooperative Supply and Marketing Federation Limited, Gangtok Sikkim

ITA 1583/KOL/2024[2020-21]Status: DisposedITAT Kolkata18 Jun 2025AY 2020-21

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 250Section 80P

…आयकर अपीलीय अधिकरण कोलकाता 'ए' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘A’ BENCH, KOLKATA श्री प्रदीप कुमार चौबे, न्याधयक सदस्य एवं श्री राकेश धमश्रा, लेखा सदस्य के समक्ष Before SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER I.T.A. Nos.: 1582 & 1583/KOL/2024 Assessment Years: 2018-19 & 2020-21 Deputy Commissioner of Income Sikkim State Cooperative Tax, Cir-3(2), Gangtok Supply and Marketing Vs. Federation Limited (Appellant) (Respondent) PAN: AADAS4451M Appearances: Department represented by : Sailen Samadder, Add. CIT, Sr. DR. Assessee represented by : A.…

Deputy Commissioner of Income Tax, Cir-3(2), Gangtok, Gangtok Sikkim vs. Sikkim State Cooperative Supply and Marketing Federation Limited, Gangtok Sikkim

ITA 1582/KOL/2024[2018-19]Status: DisposedITAT Kolkata18 Jun 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 250Section 80P

…आयकर अपीलीय अधिकरण कोलकाता 'ए' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘A’ BENCH, KOLKATA श्री प्रदीप कुमार चौबे, न्याधयक सदस्य एवं श्री राकेश धमश्रा, लेखा सदस्य के समक्ष Before SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER I.T.A. Nos.: 1582 & 1583/KOL/2024 Assessment Years: 2018-19 & 2020-21 Deputy Commissioner of Income Sikkim State Cooperative Tax, Cir-3(2), Gangtok Supply and Marketing Vs. Federation Limited (Appellant) (Respondent) PAN: AADAS4451M Appearances: Department represented by : Sailen Samadder, Add. CIT, Sr. DR. Assessee represented by : A.…

The Bank of Rajasthan Employees Credit & Thirft Cooperative Society Limited, Jaipur vs. ACIT, Circle-1, Jaipur

In the results appeal of the assessee in ITA No

ITA 213/JPR/2025[2010-2011]Status: DisposedITAT Jaipur04 Jun 2025AY 2010-2011
For Appellant: Sh. Mukesh Goyal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)

…r's Cooperative Sale Society Ltd. (Supra) we find no infirmity in the order of the Ld.CIT(A). Accordingly, the same is upheld and the grounds raised by the Revenue are dismissed. 6.3 Karnataka High Court Guttigedarara Credit Co-operative Society Ltd. vs. ITO, 377 ITR 464 (Kar.) In this case Hon ble Court after considering the judgements of various High courts and Supreme Court Hon'ble Court held as under Para No 12 page No 3 of the order "12. In the instant case, the amount which was invested in banks to earn interest was not an amount due to any members. It was not the liability. It was not shown as liability in…

Dhatrigram Niralgachi Samabay Krishi Unnayan Samity Limited, West Bengal, Purba Bardhaman vs. Income Tax Officer, Ward-1(3), Burdwan

Appeal of the assessee is allowed

ITA 2557/KOL/2024[2017-18]Status: DisposedITAT Kolkata07 May 2025AY 2017-18

Bench: SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 250Section 80P

…l cases and some of the same may be mentioned: (a) Mavilayi Service Cooperative Bank [431 ITR 1 (SC)] (b) Anna Saheb Patil Mathadi Kamgar Sahakri Patpedi Ltd. [454 ITR 117 (SC)] and (c) The case of Guttigedarara Credit Cooperative Society Limited reported in 377 ITR 464 (Karnataka) 3. Before us, the Ld. AR relied on several case law to distinguish his case from that of the case of Totagars (supra). He pointed out that they are an agricultural credit society where an account with Axis Bank has been maintained for providing better services to its members, who deposit cheques etc. in the bank account. The Ld. AR r…

The Secondary Teachers Co-Operative Credit Society Limtied, Dharwad vs. Income Tax Officer, Ward-1(1), Hubli

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2383/BANG/2024[2021-22]Status: DisposedITAT Bangalore05 May 2025AY 2021-22

Bench: Shri Waseem Ahmedassessment Year: 2021-22

For Appellant: Shri Atul Alur, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 57(2)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…Credit Cooperative Ltd (supra) that the term “attributable to” should be given a broader meaning, encompassing income derived from the temporary parking of surplus funds. Supporting precedents like Guttigedarara Credit Co-operative Society Ltd. vs. ITO [2015] 377 ITR 464 (Karnataka) were cited to affirm the claim that such interest income is a part of the operational income and eligible for deduction under the said provision. 9.1 On the other hand, the learned DR before me vehemently supported the order of the authorities below. 10. I have carefully considered the submissions of the learned Authorized Represent…

The Jyoti Co-Operative Non Agricultural Thrift & Credit Society Ltd., Sirmour vs. ITO, Ward, Nahan

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 162/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh12 Feb 2025AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं . / ITA No.160, 161 & 162/ Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18, 2012-13 & 2013-14 The Jyoti Co-operative Non Agricultural Thrift & Credit Society Ltd. Sirmour, Solan, HP-173025 स्थायी लेखा सं. / PAN NO: AAABT1453G अपीलार्थी/Appellant बनाम The ITO H.P Ward-Nahan, Sirmour प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, Advocate राजस्व की ओर से / Revenue by : Dr. Ranjeet K

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

…income of the society and it was submitted that in the instant case, no such rider exists in the bye laws. Further reliance was placed on the decision of Hon’ble Karnataka High Court in case of Guttigedarara Credit Cooperative Society Ltd. vs. ITO reported in 377 ITR 464, Hon’ble Andhra Pradesh High Court decision in case of CIT Vs. Andhra Pradesh State Co-operative Bank Ltd. reported in 336 ITR 516, Hon’ble Gujarat High Court in case of CIT Vs. Baroda Peoples Co-operative Bank Ltd. reported in 280 ITR 282 and Hon’ble Karnataka High Court in case of Tumkur Merchants Southarda Credit Cooperative Ltd. Vs. ITO (2015…

The Jyoti Co-Operative Non Agricultural Thrift & Credit Society Ltd., Sirmour vs. ITO, Ward, Nahan

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 161/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh12 Feb 2025AY 2012-13

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

…income of the society and it was submitted that in the instant case, no such rider exists in the bye laws. Further reliance was placed on the decision of Hon’ble Karnataka High Court in case of Guttigedarara Credit Cooperative Society Ltd. vs. ITO reported in 377 ITR 464, Hon’ble Andhra Pradesh High Court decision in case of CIT Vs. Andhra Pradesh State Co-operative Bank Ltd. reported in 336 ITR 516, Hon’ble Gujarat High Court in case of CIT Vs. Baroda Peoples Co-operative Bank Ltd. reported in 280 ITR 282 and Hon’ble Karnataka High Court in case of Tumkur Merchants Southarda Credit Cooperative Ltd. Vs. ITO (2015…

The Jyoti Co-Operative Non Agricultural Thrift & Credit Society Ltd., Sirmour vs. ITO, Ward, Nahan

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 160/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh12 Feb 2025AY 2017-18
For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

…income of the society and it was submitted that in the instant case, no such rider exists in the bye laws. Further reliance was placed on the decision of Hon’ble Karnataka High Court in case of Guttigedarara Credit Cooperative Society Ltd. vs. ITO reported in 377 ITR 464, Hon’ble Andhra Pradesh High Court decision in case of CIT Vs. Andhra Pradesh State Co-operative Bank Ltd. reported in 336 ITR 516, Hon’ble Gujarat High Court in case of CIT Vs. Baroda Peoples Co-operative Bank Ltd. reported in 280 ITR 282 and Hon’ble Karnataka High Court in case of Tumkur Merchants Southarda Credit Cooperative Ltd. Vs. ITO (2015…

Southern Railway Employees Cooperative Credit Society Ltd., Tiruchirappalli vs. DCIT, Cricle-1(1), Trichy

In the result, appeal filed by the assessee is allowed

ITA 2426/CHNY/2024[2017-18]Status: DisposedITAT Chennai05 Feb 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.G. Baskar, AdvocateFor Respondent: Ms.Sheila Parthasarthy
Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…ny/2019 by order dated 30.09.2020], this Tribunal while deciding similar issue on identical facts has relied upon the decision in the case of the Hon’ble Karnataka High Court in the case of Guttigedarara Credit Co-operative Society Ltd. v. ITO reported in 377 ITR 464, (which was in favour of assessee) and didn’t follow the view expressed by the Hon’ble Gujarat High Court in SBI v. CIT reported in [2016] 72 taxmann.com 64 (Gujarat), by citing M/s. Southern Railway Employees Co-op. Credit Society Ltd. :: 4 :: the decision of the Hon’ble Supreme Court in the case of CIT v. Vegetable Products ltd., reported i…

Deputy Commissioner of Income Tax Central Circle 6 (1), Mumbai, Air India Building, Nariman Point vs. Buldana Urban Coop Credit Society Ltd, Buldana

In the result, the appeal filed by the Revenue is dismissed

ITA 4398/MUM/2023[2018-19]Status: DisposedITAT Mumbai30 Jan 2025AY 2018-19

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhailassessment Year : 2018-19 Deputy Commissioner Of Buldana Urban Co-Op. Credit Income Tax, Society Ltd., Central Circle-6(1), Vs. 1, Sahakar Setu, Air India Building, Hutatma Gore Path, Nariman Point, Main Road Buldana, Mumbai Buldana, Maharashtra Pan : Aaaab2567M (Appellant) (Respondent)

For Appellant: Shri Mahavir Atal and Shri Vinod GandhiFor Respondent: Shri Kailash C. Kanojiya, CIT-DR
Section 80Section 80PSection 80P(2)(a)

…onalized banks is part of its business income and hence eligible for deduction u/s 80P(a)(i) of the Act. The relevant observations made by the Ld CIT(A) are extracted below:- “Hon‟ble Karnataka High Court in the case of Guttigedarara Cooperative Society Ltd (377 ITR 464) has also held that the interest income derived on the capital, which cannot be immediately lent to members and which is deposited in banks, is attributable to the profits and gains of the business of providing credit facilities to its members. The relevant extracts are as under: "7.From the aforesaid facts and rival contentions, the undisputed f…