How many judgments cite CIT v. Karnataka State Co-operative Apex Bank?

106 judgments on BharatTax cite CIT v. Karnataka State Co-operative Apex Bank (251 ITR 194), spanning 2011 to 2026.

Which sections of the Income Tax Act does CIT v. Karnataka State Co-operative Apex Bank come up under?

It is most often cited in judgments turning on Section 80P(2)(a)(i), Section 80P(2)(d), Section 80P(4), Section 56, Section 57, Section 80P.

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 56 Section 57 Section 80P Section 250 Section 143(3)

Issues it is cited on

section 80(p)(4)section 80(p)(2)section 58 section 80p(2)(a)(iii)section 63 section 64 section 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

Nagini Co-Operative 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 25/BANG/2025[2016-17]Status: DisposedITAT Bangalore08 Apr 2025AY 2016-17

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…

Prathamik Krishi Pattin Sahakari Sangh Niyamit Albal, Albal, Jamkhandi vs. ITO Ward-1 and Tps, Bagalkot

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

ITA 1538/BANG/2024[2018-19]Status: DisposedITAT Bangalore07 Mar 2025AY 2018-19

Bench: Shri Waseem Ahmedassessment Year: 2018-19

For Appellant: Sri G. Aralikatti, A.RFor Respondent: Sri Ganesh R Ghale, Standing counsel for department

Section 57Section 80PSection 80P(2)(a)

…As regards the compulsory deposit with the Co-operative bank, in my considered view, the issue is squarely covered in favour of the assessee by the judgement of Hon’ble Supreme Court in the case of CIT versus Karnataka State cooperative 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 t…

The Belthangady Co-Operative Agricultural Sangha Limited, Belthangady vs. Income Tax Officer, Ward-1, Puttur

ITA 1943/BANG/2024[2017-18]Status: DisposedITAT Bangalore28 Jan 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Krishna Kantila, C.AFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Dept

Section 18Section 2Section 80PSection 80P(2)(a)

…operative bank under the guidelines of Karnataka Co-operative Societies Act, then the interest thereon is eligible for deduction u/s 80P(2)(a)(i) of the Act. The Hon’ble Supreme Court in the case of CIT versus Karnataka State cooperative apex bank reported in 251 ITR 194 vide order dated 22 August 2001 has directed to allow deduction of the same under the provisions of section 80P(2)(a)(i) of the Act. The relevant extract of the judgement is reproduced as under: . ITA No.1927 & 1943/Bang/2024 Page 11 of 16 There is no doubt, and it is not disputed, that the assessee-co-operative bank is required to place a pa…

The Belthangady Co-Operative Agricultural Sangha Limited, Belthangady vs. Income Tax Officer, Ward-1, Puttur

In the result appeal of the assessee is hereby partly allowed for

ITA 1927/BANG/2024[2018-19]Status: DisposedITAT Bangalore28 Jan 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Krishna Kantila, C.AFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Dept

Section 18Section 2Section 80PSection 80P(2)(a)

…operative bank under the guidelines of Karnataka Co-operative Societies Act, then the interest thereon is eligible for deduction u/s 80P(2)(a)(i) of the Act. The Hon'ble Supreme Court in the case of CIT versus Karnataka State cooperative apex bank reported in 251 ITR 194 vide order dated 22 August 2001 has directed to allow deduction of the same under the provisions of section 80P(2)(a)(i) of the Act. The relevant extract of the judgement is reproduced as under: ITA No.1927 & 1943/Bang/2024 Page 11 of 16 There is no doubt, and it is not disputed, that the assessee-co-operative bank is required to place a part of…

Shri Vidhyut Board Credit and Consumers Co Operative Society Limited, Bhavnagar vs. A.C.I.T., Circle-1, Bhavnagar

ITA 1057/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad16 Jan 2025AY 2017-18

Bench: Ms. Suchitra Kamble

Section 142(1)Section 143(2)Section 144BSection 2(19)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…from State Bank of India of Rs.1,08,418/- considering as not eligible for deduction u/s.80P(2)(a) of the Act overlooking various judicial pronouncement including hon Supreme Court decision in the case of CIT vs. Karnataka State Co- operative Apex Bank (2001) 251 ITR 194 (SC) . 7. The Learned Additional Commissioner of Income Tax (A)-VI has erred in law and on facts and in the circumstance of case in confirming addition for the interest income of Rs.15,06,097/- earned on Deposit with SBI and Saurashtra Gramin Bank (RRB) considering the same as not eligible for deduction u/s.80P(2) of the Act. 8. The Learned Addit…

Income Tax Officer, Aayakar Bhawan Dakshin vs. Sanhati Co-Operative Credit Society Limited, Kolkata

In the result, appeal filed by the Revenue is dismissed

ITA 1366/KOL/2023[2021-22]Status: DisposedITAT Kolkata29 Nov 2024AY 2021-22

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Section 143(3)Section 250Section 56Section 68Section 80PSection 80P(2)(a)

…Act allows deduction to cooperative society engaged in banking or providing credit facilities to its members. The ld. Counsel for the assessee submits that hon Karnataka High Court in the case of CIT vs. Karnata State Cooperative Apex Bank reported in [2001] 251 ITR 194 (SC) has been held that investment in fixed deposit by cooperative society is a banking activity and the interest income earned thereon is a business income. The ld. Counsel for the assessee further submits that entire interest income earned from the investment has already been considered under the ambit of Section 80P(2)(a)(i) of the Act and is…

Murthedarara Seva Sahakari Sangha (N) Uppunda, Uppunda vs. ITO Ward- 1 Tps, Udupi

ITA 1474/BANG/2024[2020-21]Status: DisposedITAT Bangalore29 Nov 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Ravindra Poojari, C.AFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 8o

…operative bank under the guidelines of Karnataka Co-operative Societies Act, then the interest thereon is eligible for deduction u/s 80P(2)(a)(i) of the Act. The Hon’ble Supreme Court in the case of CIT versus Karnataka State cooperative apex bank reported in 251 ITR 194 vide order dated 22 August 2001 has directed to allow deduction of the same under the provisions of section 80P(2)(a)(i) of the Act. The relevant extract of the judgement is reproduced 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 Reserv…

The Teekoy Service Co-Operative Bank Ltd., Kottayam vs. Income Tax Officer, Kottayam

Appeal is allowed in above terms

ITA 703/COCH/2023[2018-19]Status: DisposedITAT Cochin07 Nov 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Revenue by : Smt. V. Swarnalatha, Sr. DRFor Respondent: Smt. V. Swarnalatha, Sr. DR

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

…gible for deduction. If the income is derived by a cooperative society from the business of banking or providing credit facility to its members, it will fall within the exemption. In the case of CIT vs Karnataka State Cooperative Apex Bank, reported in (2001) 251 ITR 194 (SC), it was held that interest from surplus funds kept as deposits in banks, being ancillary and incidental to the carrying on of the business of providing credit facility by the assessee cooperative society to its members is entitled to deduction u/s 80P(2)(a)(i). In banking business, it is normal to invest money in a manner that are readily av…

Nedumoncavu Rural Cooperative Society Ltd No Q1432, Kollam vs. AO W 2, Kollam

In the result, the appeal of the assessee is hereby allowed

ITA 7/COCH/2024[2017-18]Status: DisposedITAT Cochin27 Sept 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Sa No. 09/Coch/2024 (Assessment Year: 2017-18) Nedumoncavu Rural Co-Op. Income Tax Officer - 2 Society Ltd. 2Nd Floor, Aayakar Bhavan 1432, Kuzhumathikaud Vs. Near Karbala Junction Kollam 691509 Kollam 691001 [Pan: Aadan0367R] (Appellant) (Respondent)

For Appellant: Shri Sabu C.S., CAFor Respondent: Smt. Girly Albert, Sr. D.R

Section 80P(2)(a)Section 80P(2)(d)

…he impugned deposits were made by the assessee under guidelines of Karnataka Co-operative Societies Act which can be verified from page 12 of the Paper book. The Hon’ble Supreme Court in the case of CIT versus Karnataka State cooperative apex bank reported in 251 ITR 194 vide order dated 22 August 2001has directed to allow deduction of the same under the provisions of section 80P(2)(a)(i) of the Act. The relevant extract of the judgement is reproduced 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 Reserv…

K1104 Elaamuthur Primary Agricultural Co-Operative Credit Scoiety, Tiruppur vs. ITO, Ward 2(4), Tiruppur

In the result, appeals filed by the assessee for both the

ITA 1041/CHNY/2024[2017-18]Status: DisposedITAT Chennai18 Sept 2024AY 2017-18

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita Nos.: 1040 & 1041/Chny/2024 िनधा"रणवष" / Assessment Years: 2016-17 & 2017-18 K 1104 Elayamuthur Primary Income Tax Officer, Agricultural Co-Operative Credit V. Ward -2(4), Society, Tirupur. Elayamuthur, Udumalpet, Tirupur – 642 154. [Pan: Aabak-3636-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S. Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Shri. R.V. Aroonprasaad, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 23.07.2024 घोषणाकीतारीख/Date Of Pronouncement : 18.09.2024

For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. R.V. AroonPrasaad, Addl.CIT

Section 143(1)Section 143(3)Section 80PSection 80P(2)(d)Section 80P(4)

…n 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. 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 investments and short-term fixed deposits in…

K1104 Elayamuthur Promary Agricultural Co-Operative Credit Society, Tiruppur vs. ITO, Ward 2(4), Tiruppur

In the result, appeals filed by the assessee for both the

ITA 1040/CHNY/2024[2016-17]Status: DisposedITAT Chennai18 Sept 2024AY 2016-17

For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. R.V. AroonPrasaad, Addl.CIT

Section 143(1)Section 143(3)Section 80PSection 80P(2)(d)Section 80P(4)

R&De (Engrs) Employees Co-Op. Credit Society, Pune vs. ITO, Ward 7(3), Pune

In the result, the appeal of the assessee is allowed

ITA 762/PUN/2024[2021-22]Status: DisposedITAT Pune11 Sept 2024AY 2021-22

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri A.V. IyerFor Respondent: Shri Sourabh Nayak

Section 143(1)(a)Section 143(2)Section 143(3)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…आयकर अपीलीय अधिकरण “बी” न्यायपीठ पुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, PUNE BEFORE SHRI R.K. PANDA, VICE PRESIDENT AND MS. ASTHA CHANDRA, JUDICIAL MEMBER आयकर अपील सं. / ITA No.762/PUN/2024 धििाारण वर्ा / Assessment Year : 2021-22 R & DE (Engrs) Employees Co-op. Credit Income Tax Officer, Society Limited, Ward – 7(3), Pune Dighi Alandi Road, Kalas, Pune-411015 Vs. PAN : AACAR6160K अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee by : Shri A.V. Iyer Department by : Shri Sourabh Nayak Date of hearing : 08-07-2024 Date of 11-09-2024 Pronouncement : आदेश / ORDER PER ASTHA CHANDRA, JM…

DCIT, Circle, Patiala vs. M/S Punjab State Power Corporation Ltd., Patiala

In the result, ground no. 1 & 3 of the Revenue’s appeal is allowed and ground no

ITA 737/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh27 Aug 2024AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Rajiv Saldi, CAFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 143(2)

…t its circulating capital. It will be income from banking business eligible for deduction u/s 80P subject to the fulfillment of the other conditions of the section. The Hon'ble Summit Court in the case of CIT Vs. Karnataka State Co-operative Apex Bank [(2001) 251 ITR 194 (SC)] has held to this extent by laying down that "the placement of such funds being imperative for the purpose of carrying on the banking business, the income derived there from would be income from assessee's business. There is nothing in the phraseology of that provision which makes it applicable only to income derived from working or circulat…

Hassan Co-Operative Milk Producers Societies Union Limited, Hassan vs. Assisstant Commissioner of Income Tax, Circle-1, Hassan

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

ITA 1305/BANG/2024[2020-21]Status: DisposedITAT Bangalore23 Aug 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Yogesh Kumar U.S

For Appellant: Ms. Suman Lunkar, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bengaluru

Section 250Section 57Section 7Section 80Section 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR U.S, JUDICIAL MEMBER ITA Nos. 1304-1305/Bang/2024 Assessment Years: 2018-19, 2020-21 M/s. Hassan Co-operative Milk Producers Vs. ACIT, Societies Union Ltd., Circle – 1, Diary Administrative Building, Hassan. Arasikere Road, B. M. Road, Industrial Estate, Hassan – 573 201. PAN : AAAAH 0229 B APPELLANT RESPONDENT Assessee by : Ms. Suman Lunkar, CA Revenue by : Shri. Subramanian S, JCIT(DR)(ITAT), Bengaluru. Date of hearing : 22.08.2024 Date of Pronouncement : 23.08.2024 O R D E R Per Wa…

Hassan Co-Operative Milk Producers Societies Union Limited, Hassan vs. Assisstant Commissioner of Income Tax, Circle-1, Hassan

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

ITA 1304/BANG/2024[2018-19]Status: DisposedITAT Bangalore23 Aug 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Yogesh Kumar U.S

For Appellant: Ms. Suman Lunkar, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bengaluru

Section 250Section 57Section 7Section 80Section 80P(2)(a)Section 80P(2)(d)

Ordnance Factory Bhandara Karamchari Sahakari Pat Sanstha Ltd., Bhandara vs. Assessment Unit, Income Tax Department, Delhi

Appeal is allowed in above terms

ITA 28/NAG/2023[2020-21]Status: DisposedITAT Nagpur01 May 2024AY 2020-21

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Kapil Hirani, AdvocateFor Respondent: Shri Abhay Y. Marathe

Section 143(3)Section 80P(2)(a)

…i.e., Statutory Liquidity Ratio as mandatory compliance of the various banking norms applicable in case of a co-operative society. It is in this factual backdrop that hon’ble apex court’s landmark decision CIT vs., Karnataka State Cooperative Apex Bank [2001] 251 ITR 194 (SC) and CIT vs. Nawanshahar Central Cooperative Bank Ltd., [2007] 289 ITR 6 (SC) have already settled the issue in assessee’s favour and against the department that such an interest derived from deposits of SLR funds duly qualifying for sec.80P(2)(a)(i) deduction. That being the 3 ITA.No.28/NAG./2023 clinching case, I accept the assessee’s insta…

Gohana Co-Op Marketing Processing Society Ltd, Gohana vs. Income Tax Officer, Sonipat

In the result, the appeal of the assessee is dismissed

ITA 2698/DEL/2023[2018-19]Status: DisposedITAT Delhi30 Apr 2024AY 2018-19

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar[Assessment Year : 2018-19] Gohana Co-Op Marketing Vs Ito, Processing Society Ltd., Shop No.1, Sonipat. New Anaj Mandi, Gohana, Sonipat, Haryana-131301 Pan-Aaaag0108Q Appellant Respondent Appellant By None Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 24.04.2024 Date Of Pronouncement 30.04.2024 Order

Section 143(2)Section 56Section 80P(2)(a)

…ins of business” and thus deductible under section 80P(2)(a)(i) of the Income Tax Act, 1961. This has been so held in Bihar State Co-operative Bank Ltd. v CIT [1960] 39 ITR 114(SC), CIT vs Karnataka State Co-operative Apex Bank [2001] Supp. (2) SCR 35; [2001] 251 ITR 194 (SC) and CIT v. Ramanathapuram District Co-operative Central Bank Ltd. [2002] 255 ITR 423 (SC). The principle in these cases would also cover a situation where a co- operative bank carrying on the business of banking is statutorily required to place a part of its funds in approved securities. The appeals are accordingly dismissed without costs.”…

M/S.the Mundakkayam Service Co-Op Bank Ltd, Kottayam vs. The ITO, Kottayam

ITA 73/COCH/2023[2018-19]Status: DisposedITAT Cochin28 Dec 2023AY 2018-19

Bench: Shri Sanjay Arora & Shri Manomohan Dasthe Mundakkayam Service Co- The Income Tax Officer Operative Bank Ltd. Ward – 2 Mundakkayam Vs. Kottayam Kottayam 686513 [Pan:Aaaat8803H] (Appellant) (Respondent)

For Appellant: Shri Prasanth Srinivas, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R

Section 143(3)Section 5Section 59Section 80P(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Manomohan Das, Judicial Member The Mundakkayam Service Co- The Income Tax Officer operative Bank Ltd. Ward – 2 Mundakkayam vs. Kottayam Kottayam 686513 [PAN:AAAAT8803H] (Appellant) (Respondent) Assessee by: Shri Prasanth Srinivas, CA Revenue by: Smt. J.M. Jamuna Devi, Sr. D.R. Date of Hearing: 17.10.2023 Date of Pronouncement: 28.12.2023 O R D E R Per Sanjay Arora, AM This is an Appeal by the Assessee agitating the dismissal of it’s appeal contesting it’s assessment under section 143(3) r/ws. 144B of…

M/S. Dodmane Group Gramagala Seva Sahakari Sangha Niyamita Karkimaki, Karkimakki vs. Income Tax Officer, Ward-1, Sirsi

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

ITA 751/BANG/2023[2018-19]Status: DisposedITAT Bangalore21 Nov 2023AY 2018-19

Bench: Shri George George Kassessment Year : 2018-19 Sri Dodmane Group Gramagala Seva Sahakari Vs. Ito, Sangha Niyamita Karkimakki, Ward – 1, 41, Siddapur-Kumta Road Karkimakki Sirsi. Tq 581 322, Karnataka. Pan : Aacad 0741 J Appellant Respondent Assessee By : Ms. Sunaina Bhatia, Ca Revenue By : Shri. Ganesh R Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 21.11.2023 Date Of Pronouncement : 21.11.2023

For Appellant: Ms. Sunaina Bhatia, CAFor Respondent: Shri. Ganesh R Ghale, Advocate, Standing Counsel for Revenue

Section 143(2)Section 234Section 250Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…ase of M/s Totagar Co-operative Sales Society Ltd. vs. ITO 322 ITR 2023 (SC) and Banglore Club vs CIT 29 Taxmann.com 29 (SC) whereas the appellant has relied upon the cases of Hon'ble Supreme Court in the case of CIT vs. Karnataka State Co-operative Apex Bank 251 ITR 194 (SC) and Bagalkot District Central Co-operative Bank vs. Joint Commissioner, Bijapur Range 48 Taxmann.com 117 (Banglore-Tribunal) and PCIT Hubbali vs. Totagar Co-operative Sales Society 392 ITR 74. 6.1 The primary issue in this case is whether such interest income is eligible for the deduction u/s 80P(2)(a)(i) or u/s 80P(2)(d). The Hon'ble Karnat…

Assistant Commissioner of Income Tax, Circle-1(1), Raipur vs. Chhattisgarh Rajya Sahakari Awas Sangh (Maryadit), Raipur

In the result, the appeal of the revenue is dismissed in terms of our aforesaid observations

ITA 206/RPR/2022[2015-16]Status: DisposedITAT Raipur16 Oct 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 206/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Chhattisgarh Rajya Sahkari Awas Sangh Maryadit C-191, Tagore Nagar, Raipur (C.G.) Pan : Aaaac5903F ……""यथ" / Respondent

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 143(3)Section 147Section 148Section 80PSection 80P(2)(a)Section 80P(2)(d)

…embers fell within the realm of sub-section (2)(a)(i) of Section 80P of the Act. In support of its aforesaid contention, the assessee society had relied on the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Karnataka State Cooperative Apex Bank, 251 ITR 194 (SC) and that of Special Bench of the Tribunal in the case of Surat District Co- operative Bank, 85 ITD 1. 5. Apart from that, the assessee society, in order to buttress its claim that interest earned on saving bank/fixed deposits with commercial banks was its business income, had drawn support from the order of the ITAT, Indore in ACIT Vs. M/s.…