CIT v. Karnataka State Co-operative Apex Bank

251 ITR 194Supreme Court of India2001#1023 most cited

What is CIT v. Karnataka State Co-operative Apex Bank authority for?

Interest income earned by a co-operative bank from statutory investments or mandatory deposits, which are essential for conducting its banking business, qualifies as business income and is exempt under Section 80P(2)(a)(i) of the Income-tax Act.

106

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Karnataka State Co-operative Apex Bank · 251 ITR 194 · Section 80P(2)(a)(i) · co-operative bank interest income · statutory deposits exemption · mandatory investments 80P · business income co-operative society · reserve fund interest · banking business income tax exemption

Also reported as

118 Taxmann 321

Sections most often in play

Section 80P(2)(a)(i)Section 80P(2)(d)Section 80P(4)Section 56Section 57Section 80PSection 250Section 143(3)

Issues it is cited on

section 80(p)(4)section 80(p)(2)section 58section 80p(2)(a)(iii)section 63section 64section 5(b)section 80p(4)section 80p(1)section 2(19)section 80p(2)(a)section 80p(2)(a)(i)

Judgments citing CIT v. Karnataka State Co-operative Apex Bank

Aurangabad Division Life Insurance Employees Co-Op Credit Society Ltd, Auranbad vs. ITO, Ward-1(1), Aurangabad

In the result, appeal of the assessee is allowed

ITA 3175/PUN/2025[2020-21]Status: DisposedITAT Pune10 Feb 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3175/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Aurangabad Divison Life V The Income Tax Officer, Insurance Employees Co-Op S Ward-1(1), Aurangabad. Credit Society Ltd., 11, Jeevan Prakash, Lic Office Building Adalat Road, Kranti Chowk, Aurangabad -431005 Pan: Aaaaa2245A Appellant/ Assessee Respondent /Revenue Assessee By Ca Payal Rathi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 09/02/2026 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 24.09.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Income Tax Act, 1961

Section 143(3)Section 144BSection 250Section 56Section 66Section 80PSection 80P(2)(a)

…om availing of the deduction. The distinction between eligibility for deduction and attributability of amount of profits and gains to an activity is a real one.” 3.4 The Hon’ble Supreme Court in the case of CIT vs Karnataka State Co-operative Apex bank [2001] 251 ITR 194 (SC) observed as under : Quote, “The question in appeal reads : "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the interest income arising from the investment made out of reserve fund is exempt under section 80P(2)(a)(i ) of the Income-tax Act, 1961 ?" 4. While deciding the abo…

Income Tax Officer Ward 1 Satara, Satara vs. Karad Patan Taluka Prathmik Shikshak Sahakari Society Limitedty, Karad

In the result, Revenue’s Appeal is dismissed

ITA 2289/PUN/2025[2020]Status: DisposedITAT Pune23 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2289/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Income Tax Officer, V Karad Patan Taluka Prathmik Ward-1, Satara. S Shikshak Sahakari Society Limited, 190 B Shaniwar Peth, Opp.Shivneri Lodge, Karad, Satara – 415110 Pan: Aaaak0559R Appellant / Assessee Respondent / Revenue Assessee By Shri Satish U Nade Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated

Section 143(3)Section 144BSection 250Section 56Section 57Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…on. The distinction between eligibility for deduction and attributability of amount of profits and gains to an activity is a real one.” 9 ITA No.2289/PUN/2025 [A] 10.2 Hon’ble Supreme Court in the case of CIT vs Karnataka State Co-operative Apex bank [2001] 251 ITR 194 (SC) observed as under : Quote,“The question in appeal reads : "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the interest income arising from the investment made out of reserve fund is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961?"Unquote. 10.2.1 While decidi…

Income Tax Officer Ward-2, Ahmednagar, Ahamednagar vs. Kanifnath Grmain Bigar Sheti Sahakaripatsanstha Maryadit, Maldad

In the result, Revenue’s Appeal is dismissed

ITA 2271/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…on fromavailing of the deduction. The distinction between eligibility for deduction and attributability of amount ofprofits and gains to an activity is a real one.” 8.2 Hon’ble Supreme Court in the case of CIT vs Karnataka State Co-operative Apex bank [2001] 251 ITR 194 (SC) observed as under : Quote,“The question in appeal reads : "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the interest income arising from the investment made out of reserve fund is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961?"Unquote. 9 ITA Nos.2270 & 22…

Income Tax Officer Ward-2, Ahmednagar vs. Kanifnath Grmain Bigar Sheti Sahakari, Maldad Sangamner

In the result, Revenue’s Appeal is dismissed

ITA 2270/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…on fromavailing of the deduction. The distinction between eligibility for deduction and attributability of amount ofprofits and gains to an activity is a real one.” 8.2 Hon’ble Supreme Court in the case of CIT vs Karnataka State Co-operative Apex bank [2001] 251 ITR 194 (SC) observed as under : Quote,“The question in appeal reads : "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the interest income arising from the investment made out of reserve fund is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961?"Unquote. 9 ITA Nos.2270 & 22…

Sri Bramaramba Pattina Souharda Shakari Sangha Niyamitha, Maski vs. Income Tax Officer, Ward-1, Raichur

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

ITA 189/BANG/2025[2020-21]Status: DisposedITAT Bangalore05 Jan 2026AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri Siva Prasad Reddy, ITPFor Respondent: Shri Subramanian .S, JCIT-DR
Section 142(1)Section 143(2)Section 71Section 80PSection 80P(2)Section 80P(2)(a)

…] 123 taxmann.com 161 (SC), which is in favour of the assessee. 2. The learned AO as well as the Learned CIT(A) erred in not following the binding judgment of the Hon'ble Supreme Court, Larger Bench in the case of Karnataka State Apex Co-operative Bank (2001) 251 ITR 194 (SC), which has settled the controversy holding that the interest income accruing on statutory reserves is eligible for the deduction u/s 80P(2)(a)(i) of the Act. 3. Without prejudice to any of the submissions and Grounds taken, the learned assessing office erred in not appreciating that the expenditure to be deducted proportionately against the…

Urban Co-Operative Credit Society Limited., Ramanagara vs. Income Tax Officer, Ward-1, Ramanagara

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

ITA 1156/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri H. Siva Prasad Reddy, ITPFor Respondent: Shri Subramanian S, JCIT-DR
Section 143(2)Section 44ASection 57Section 58Section 68Section 80PSection 80P(2)(a)

…ative Ltd. vs. ITO reported in (2015) 55 taxmann.com 447 (Karnataka). 10. The above said view was also approved by the Constitutional Bench judgment of the Hon’ble Supreme Court in the case of CIT vs. Karnataka State Co-operative Apex Bank reported in [2001] 251 ITR 194. Therefore we are also following the Constitutional Bench judgment of the Hon’ble Supreme Court as well as the judgment of the Hon’ble Jurisdictional High Court and hold that if the assessee is able to demonstrate that the deposits are made pursuant to the mandatory provisions contained in the Karnataka Co-operative Societies Act, then the same i…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2405/CHNY/2025[2018-19]Status: DisposedITAT Chennai28 Nov 2025AY 2018-19

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

…the shape of F.D.Rs. is income derived from banking business and therefore, eligible for deduction under Section 80 P (2) (a) (i) of the Income Tax Act?” 8. After considering the decisions in CIT Vs. Karnataka State Co- operative Apex Bank reported in [2001] 251 ITR 194, CIT Vs. ITA Nos.2401 to 2405/Chny/2025 :- 8 -: Ramanathapuram District Co-operative Central Bank Ltd reported in [2002] 255 ITR 423 (SC), a Division Bench of the Himachal Pradesh High Court, at paragraph Nos.10 and 11 held thus:- “The Karnataka High Court in CIT Vs. Sri Ram Sahakari Bank Ltd., [2004] 266 ITR 632, held that the interest on in…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2404/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Nov 2025AY 2017-18

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

…the shape of F.D.Rs. is income derived from banking business and therefore, eligible for deduction under Section 80 P (2) (a) (i) of the Income Tax Act?” 8. After considering the decisions in CIT Vs. Karnataka State Co- operative Apex Bank reported in [2001] 251 ITR 194, CIT Vs. ITA Nos.2401 to 2405/Chny/2025 :- 8 -: Ramanathapuram District Co-operative Central Bank Ltd reported in [2002] 255 ITR 423 (SC), a Division Bench of the Himachal Pradesh High Court, at paragraph Nos.10 and 11 held thus:- “The Karnataka High Court in CIT Vs. Sri Ram Sahakari Bank Ltd., [2004] 266 ITR 632, held that the interest on in…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2403/CHNY/2025[2016-17]Status: DisposedITAT Chennai28 Nov 2025AY 2016-17

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

…the shape of F.D.Rs. is income derived from banking business and therefore, eligible for deduction under Section 80 P (2) (a) (i) of the Income Tax Act?” 8. After considering the decisions in CIT Vs. Karnataka State Co- operative Apex Bank reported in [2001] 251 ITR 194, CIT Vs. ITA Nos.2401 to 2405/Chny/2025 :- 8 -: Ramanathapuram District Co-operative Central Bank Ltd reported in [2002] 255 ITR 423 (SC), a Division Bench of the Himachal Pradesh High Court, at paragraph Nos.10 and 11 held thus:- “The Karnataka High Court in CIT Vs. Sri Ram Sahakari Bank Ltd., [2004] 266 ITR 632, held that the interest on in…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi-II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2401/CHNY/2025[2013-14]Status: DisposedITAT Chennai28 Nov 2025AY 2013-14

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

…the shape of F.D.Rs. is income derived from banking business and therefore, eligible for deduction under Section 80 P (2) (a) (i) of the Income Tax Act?” 8. After considering the decisions in CIT Vs. Karnataka State Co- operative Apex Bank reported in [2001] 251 ITR 194, CIT Vs. ITA Nos.2401 to 2405/Chny/2025 :- 8 -: Ramanathapuram District Co-operative Central Bank Ltd reported in [2002] 255 ITR 423 (SC), a Division Bench of the Himachal Pradesh High Court, at paragraph Nos.10 and 11 held thus:- “The Karnataka High Court in CIT Vs. Sri Ram Sahakari Bank Ltd., [2004] 266 ITR 632, held that the interest on in…

The Sangli Salary Earners Co Op Society Ltd, Sangli vs. Income Tax Officer Ward 3 Sangli, Sangli

In the result, appeal of the assessee is allowed

ITA 2254/PUN/2025[2020-21]Status: DisposedITAT Pune17 Nov 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2254/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 The Sangli Salary Earners Co V The Income Tax Officer, Op Society Ltd., S. Ward-3, Sangli. 1104 B, Harbhat Road, Main City, Sangli – 416416 Pan: Aaaat0980D Appellant/ Assessee Respondent / Revenue Assessee By Shri Amit Sudhir Shintre(Virtual) Revenue By Smt. Saumya Pandey Jain-Addl.Cit Date Of Hearing 17/11/2025 Date Of Pronouncement 17/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 27.08.2025 Emanating From Assessment Order U/S.143(3) Read With Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 Dated 26.09.2022. The Assessee Has Raised Following Grounds Of Appeal : “1. Deduction U/S 80P(2)(A)(I) Relying On The Decision Of Totgars Co-

Section 143(3)Section 250Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)Section 80P(4)

…eld that Interest Income earned by investing Income derived from Business and Profession by a Co-Operative Society was eligible for deduction u/s.80P(2)(a) of the Act. 8. The Hon’ble Supreme Court in the case of CIT Vs. Karnataka State Co-operative Apex Bank 251 ITR 194 (SC) vide order dated 22.08.2001 has held as under : Quote“6..…………………There is no doubt, and it is not disputed, that the assessee-co-operative bank is required to place a part of its funds with the State Bank or the Reserve Bank of India to enable it to carry on its banking business. This being so, any income derived from funds so placed arises f…

Maratha Seva Sangh Sanchlit Dhule Dist Nagari Sahakari Patsanstha Ltd, Dhule vs. Assessment Unit, Itd, Delhi

In the result, appeal of the assessee is allowed

ITA 2183/PUN/2025[2015-16]Status: DisposedITAT Pune14 Nov 2025AY 2015-16

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2183/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Maratha Seva Sangh Sanchlit V Assessment Unit, Dhule Dist Nagari Sahakari S Itd. Patsanstha Ltd., Plot No.148, Chudamani, Jay Hind Colony, Deopur Dhule, Dhule – 424002. Pan: Aactm4087D Appellant/ Assessee Respondent / Revenue Assessee By Shri Sharad A Shah Revenue By Shri Pawan Bharti (Virtual Hearing) Date Of Hearing 13/11/2025 Date Of Pronouncement 14/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Dated 23.07.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 21.02.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 142(1)Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ngaged in banking business i.e. engaged in lending money to members of the public, which have a licence in this behalf from the RBI.” Unquote. ITA No.2183/PUN/2025 [A] 9. The Hon’ble Supreme Court in the case of CIT Vs. Karnataka State Co-operative Apex Bank 251 ITR 194 (SC) vide order dated 22.08.2001 has held as under : Quote“6..…………………There is no doubt, and it is not disputed, that the assessee-co-operative bank is required to place a part of its funds with the State Bank or the Reserve Bank of India to enable it to carry on its banking business. This being so, any income derived from funds so placed arises f…

Pandit Dindayal Upahyey Nagari Sahakari Patpedhi Ltd, Shahada vs. ITO, Ward 1, Dhule

In the result, appeal of the assessee is allowed

ITA 1409/PUN/2025[2017-18]Status: DisposedITAT Pune14 Nov 2025AY 2017-18

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1409/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Pandit Dindayal Upahyey V The Income Tax Officer, Nagari Sahakari Patpedhi Ltd., S Ward -1, Dhule. Near Bohari Market Dondaicha Road, Shahade – 425409. Maharashtra. Pan: Aaald0407C Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Pawan Bharti –Dr(Virtual Hearing) Date Of Hearing 12/11/2025 Date Of Pronouncement 14/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 24.02.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 25.11.2019. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 250Section 56Section 80PSection 80P(2)Section 80P(2)(a)

…gaged in banking business i.e. engaged in lending ITA No.1409/PUN/2025 [A] money to members of the public, which have a licence in this behalf from the RBI.” Unquote. 9. The Hon’ble Supreme Court in the case of CIT Vs. Karnataka State Co-operative Apex Bank 251 ITR 194 (SC) vide order dated 22.08.2001 has held as under : Quote“6..…………………There is no doubt, and it is not disputed, that the assessee-co-operative bank is required to place a part of its funds with the State Bank or the Reserve Bank of India to enable it to carry on its banking business. This being so, any income derived from funds so placed arises f…

Income Tax Officer, Ward-1, Hospet vs. Gayatri Pattina Souharda Sahakari Sangha Niyamitha, Hospet

ITA 1078/BANG/2024[2017-18]Status: DisposedITAT Bangalore17 Jul 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Balram R Rao, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 143(1)Section 143(3)Section 194ASection 250Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…s other than the actual conduct of the business of generation and distribution of electricity" 9.9 Further, we also draw support and guidance from the judgment of Hon'ble Supreme Court in the case of CIT Vs. Karnataka State Co-operative Apex Bank reported in 251 ITR 194 wherein it was held as under: “There is no doubt, and it is not disputed, that the assessee co-operative bank is required to place a part of its funds with the State Bank or the Reserve Bank of India to enable it to carry on its banking business. This being so, any income derived from funds so placed arises from the business carried on by it and…

Income Tax Officer, Ward-7(2)(1), Bengaluru, Bangalore vs. M/S. Bangalore Credit Co-Operative Society Limited, Bangalore

ITA 2348/BANG/2024[2020-21]Status: DisposedITAT Bangalore30 Jun 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 250

…f Rs. 45,91,489/- is earned from the Reserve funds which has to be mandatorily maintained by a co-operative society as per the provisions of Karnataka Co- operative Society Act, 1959. The Hon’ble Supreme Court in CIT Vs Karnataka State Co-operative Apex Bank (251 ITR 194) has held that interest arising from investment made, in compliance with statutory provisions to enable it to carry on banking business, out of reserve fund by a co-operative society engaged in banking business, is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961. The placement of such funds being imperative for the purpose of carryi…

Income-Tax Officer, Ward-7(2)(1), Bengaluru vs. M/S. Bangalore Credit Co-Operative Society Limited, Bengaluru

ITA 2347/BANG/2024[2018-19]Status: DisposedITAT Bangalore30 Jun 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Sri Sandeep Chalapathy, A.R
Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of Rs.45,91,489/- is earned from the Reserve funds which has to be mandatorily maintained by a co-operative society as per the provisions of Karnataka Co- operative Society Act, 1959. The Hon'ble Supreme Court in CIT Vs Karnataka State Co-operative Apex Bank (251 ITR 194) has held that interest arising from investment made, in compliance with statutory provisions to enable it to carry on banking business, out of reserve fund by a co-operative society engaged in banking business, is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961. The placement of such funds being imperative for the purpose of carryi…

M/S. Shree Vijayalaxmi Souharda Sahakari Niyamita, Sirsi vs. Income Tax Officer, Ward-1, Sirsi

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

ITA 1997/BANG/2024[2020-21]Status: DisposedITAT Bangalore30 Jun 2025AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

For Respondent: Ms. Sunaina Bhatia
Section 234Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

…he statutory deposits are concerned but only to arrive correct quantum of income, the Ld.CIT(A) had remitted the issue to the file of the AO. 10. The said view taken by the Ld.CIT(A) is in accordance with the judgment of the Hon’ble Supreme Court reported in 251 ITR 194 in the case of CIT vs. Karnataka State Co-operative Apex Bank wherein it was held as under: “Interest arising from investment made, in compliance with statutory provisions to enable it to carry on banking business, out of reserve fund by a co-operative society engaged in banking business, is exempt under section 80P(2)(a)(i) of the Income-tax Act…

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

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 475/BANG/2025[2014-15]Status: DisposedITAT Bangalore25 Jun 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2014-15

For Appellant: Ms. Sunaina Bhatia, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate, Standing
Section 57Section 80P(2)(a)

…mpliance with the Karnataka Cooperative Societies Act. Therefore, it was operational in nature and eligible for deduction. In support, reliance was placed on the Hon’ble Supreme Court's decision in the case of Karnataka State Cooperative Apex Bank reported in 251 ITR 194, where it was held that interest on such deposits made as part of statutory obligation or to maintain liquidity was deductible under section 80P(2)(a)(i) of the Act. 3.1 With regard to locker rent, the learned AR submitted that it formed part of the regular banking and financial activity of the society and hence qualifies as income from providin…

Nagini Cooperative Credit Society Limited, Bangalore vs. Income Tax Officer, Ward-6(2)(1), Bangalore

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 27/BANG/2025[2020-21]Status: DisposedITAT Bangalore08 Apr 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Gireesha T L, CAFor Respondent: Shri Subramanian .S, JCIT-DR
Section 20Section 57Section 58Section 80P(2)(a)

…direction. 18. In respect of the statutory deposits made by the co-operative societies, the Constitutional Bench of the Hon’ble Supreme Court in the case of CIT Page 14 of 15 ITA Nos. 25 to 27/Bang/2025 Vs. Karnataka State Co-operative Apex Bank reported in 251 ITR 194, had held as follows: “Interest arising from investment made, in compliance with statutory provisions to enable it to carry on banking business, out of reserve fund by a co-operative society engaged in banking business, is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961. The placement of such funds being imperative for the purpose o…

Nagini Cooperative Credit Society Limited, Bangalore vs. Income Tax Officer, Ward-6(2)(1), Bangalore

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 26/BANG/2025[2018-19 ]Status: DisposedITAT Bangalore08 Apr 2025

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Gireesha T L, CAFor Respondent: Shri Subramanian .S, JCIT-DR
Section 20Section 57Section 58Section 80P(2)(a)

…direction. 18. In respect of the statutory deposits made by the co-operative societies, the Constitutional Bench of the Hon’ble Supreme Court in the case of CIT Page 14 of 15 ITA Nos. 25 to 27/Bang/2025 Vs. Karnataka State Co-operative Apex Bank reported in 251 ITR 194, had held as follows: “Interest arising from investment made, in compliance with statutory provisions to enable it to carry on banking business, out of reserve fund by a co-operative society engaged in banking business, is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961. The placement of such funds being imperative for the purpose o…