CIT v. Punjab State Cooperative Bank Ltd.

300 ITR 24High Court2008#8389 most cited

What is CIT v. Punjab State Cooperative Bank Ltd. authority for?

Income of a cooperative society is exempt from tax if it falls under any of the specific heads of exemption provided in Section 80P of the Income Tax Act, as these are separate and distinct.

13

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2015 to 2024.

Also referred to as

CIT v. Punjab State Cooperative Bank Ltd. · section 80P · exemption · cooperative society · mutual benefit · heads of exemption · tax exemption · Income Tax Act

Issues it is cited on

section 56(i)(ccv)section 80p(2)(i)assessment order erroneouslack of enquirysection 80p(4)section 80p(2)(a)section 80p(2)(a)(i)section 80p(2)section 80p(2)(d)limited scrutinysection 80perroneous and prejudicial

Judgments citing CIT v. Punjab State Cooperative Bank Ltd.

The Mullanpur Garibdas Co-Op Multipurpose Society, Mohali vs. DCIT, C-6(1), Mohali

ITA 645/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh16 May 2024AY 2012-13

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Garima Singh, CIT, DR
Section 263Section 56Section 80PSection 80P(2)(d)

…)(i) of the Income Tax Act. Reliance is placed on the cases of 'Messrs Yashwant Credit Cooperative Society Limited Bengaluru Versus Department of Income Tax', reported as ITA Number 737/bang/2011 and 'ITO Versus Punjab State Cooperative Bank', reported as 300 ITR 24 (P&H). The income of the society, being for mutual benefits of its members, is also exempt from tax. Your kind attention is invited to the case of 'Bankipur Club Limited', 140 CTR 102 (SC) and 'Canara Bank Golden Jubilee Staff Welfare Fund Versus DCIT', 308 ITR 202 (Kerala) and 'Chemsford Club Limited', reported as 243 ITR 89." By way of Questio…

The Mullanpur Garibdas Co-Op Multipurpose Society, Mullanpur vs. Pr. CIT-II, Chandigarh

ITA 569/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh16 May 2024AY 2013-14

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Garima Singh, CIT, DR
Section 263Section 56Section 80PSection 80P(2)(d)

…)(i) of the Income Tax Act. Reliance is placed on the cases of 'Messrs Yashwant Credit Cooperative Society Limited Bengaluru Versus Department of Income Tax', reported as ITA Number 737/bang/2011 and 'ITO Versus Punjab State Cooperative Bank', reported as 300 ITR 24 (P&H). The income of the society, being for mutual benefits of its members, is also exempt from tax. Your kind attention is invited to the case of 'Bankipur Club Limited', 140 CTR 102 (SC) and 'Canara Bank Golden Jubilee Staff Welfare Fund Versus DCIT', 308 ITR 202 (Kerala) and 'Chemsford Club Limited', reported as 243 ITR 89." By way of Questio…

The Mullanpur Garibdas Co-Op Multipurpose Society, Mohali vs. Pr. CIT-II, Chandigarh

ITA 515/CHANDI/2017[2012-13]Status: DisposedITAT Chandigarh16 May 2024AY 2012-13

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Garima Singh, CIT, DR
Section 263Section 56Section 80PSection 80P(2)(d)

…)(i) of the Income Tax Act. Reliance is placed on the cases of 'Messrs Yashwant Credit Cooperative Society Limited Bengaluru Versus Department of Income Tax', reported as ITA Number 737/bang/2011 and 'ITO Versus Punjab State Cooperative Bank', reported as 300 ITR 24 (P&H). The income of the society, being for mutual benefits of its members, is also exempt from tax. Your kind attention is invited to the case of 'Bankipur Club Limited', 140 CTR 102 (SC) and 'Canara Bank Golden Jubilee Staff Welfare Fund Versus DCIT', 308 ITR 202 (Kerala) and 'Chemsford Club Limited', reported as 243 ITR 89." By way of Questio…

The Jhingran Coop Multipurpose Service Society Limited, Nawanshahr vs. Income Tax Officer ( TDS), Jalandhar

ITA 64/ASR/2023[2015-16]Status: DisposedITAT Amritsar20 Jun 2023AY 2015-16

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Shri Rakesh Joshi, AdvocateFor Respondent: Shri Pardeep Kumar, Sr. DR
Section 194ASection 194A(3)(v)Section 201Section 201(1)Section 80P

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH. ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A. No. 64/Asr/2023 Assessment Year: 2015-16 The Jhingran Coop. Vs. The ITO (TDS) Multipurpose Service Society Ltd. Jalandhar VPO: Jhingran, Tehsil- Banga Dist: Nawanshahr, Doaba PAN: AAATT4076F APPELLANT RESPONDENT Assessee by : Shri Rakesh Joshi, Advocate Revenue by : Shri Pardeep Kumar, Sr. DR Date of Hearing: 13/06/2023 Date of Pronouncement: 20/06/2023 ORDER Per Dr. M. L. Meena, AM: This appeal is filed by the Assessee against the order of the Ld. CIT(A)…

Beed Taluka Dhud Va vs. Ayik Sahakarisangh Ltd, Beed

The appeal is dismissed as withdrawn

ITA 293/PUN/2017[2012-13]Status: DisposedITAT Pune01 Jul 2019AY 2012-13

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: N O N E (Written request to withdraw appeal received through post)For Respondent: Shri N. Ashok Babu
Section 80PSection 80P(2)(b)

…e to the federation, as observed by the Hon. Supreme court in the case of “The Citizen Co-op Society Ltd. vs. ACIT” reported in (2017) 397 ITR 0001 (SC), dated 08/08/2017, in Para 21 giving reference of decision of CIT vs. Punjab State Co-op Bank Ltd., (2008) 300 ITR 24 (Pun & Har – HC) 21. In the case of Commissioner of Income Tax v. Punjab State Co-operative Bank Ltd., (2008) 300 ITR 24 (Punjab & Haryana H.C.), while dealing with an identical issue, the High Court of Punjab and Haryana held as follows: “8. The provisions of section 80P were introduced with a view to encouraging and promoting the growth of the c…

Beed Taluka Dhud Vasayik Sahakari Sangh Ltd, Beed vs. Income-Tax Officer, Beed

In the result, the appeal of the assessee is dismissed as ‘withdrawn’

ITA 1026/PUN/2017[2013-14]Status: DisposedITAT Pune04 Jun 2018AY 2013-14

Bench: Shri D. Karunakara Rao, Am

For Appellant: Withdrawal appln. Dt.11-05-2018For Respondent: Dr. Vivek Aggarwal
Section 80PSection 80P(2)(b)

…wable to the federation, as observed by the Hon. Supreme court in the case of "The Citizen Co-op Society Ltd vs ACIT” reported in (2017) 397 ITR 0001(SC)., dated:08/08/2017.,in Para 21 giving reference of decision of CIT vs Punjab State Co-op Bank Ltd.,(2008) 300 ITR 24 (Pun & Har-HC). “21. In the case of Commissioner of Income Tax v. Punjab State Co-operative Bank Ltd., (2008) 300 ITR 24 (Punjab & Haryana H. C. ), while dealing with an identical issue, the High Court of Punjab and Haryana held as follows: “8. The provisions of section 80P were introduced with a view to encouraging and promoting the growth of t…

Income Tax Officer, Hubli vs. M/S Kvg Bank Employees Co-Operative Credit Co-Op Society Ltd, Dharwad

ITA 671/BANG/2017[2013-14]Status: DisposedITAT Bangalore15 Nov 2017AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Laliet Kumarincome-Tax Officer, Ward 2(2), Hubballi. … Appellant Vs. M/S.Kvg Bank Employees Co-Operative Credit Co-Op Society Ltd., Shankar Plaza, 2Nd Floor, Dharwad. … Respondent Pan: Aaaak 7950 N

For Appellant: Shri M.K.Biju, JCIT(DR)For Respondent: Shri Balram Rao, Advocate
Section 143(3)Section 80Section 80PSection 80P(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, BENGALURU BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER and SHRI LALIET KUMAR, JUDICIAL MEMBER Income-tax Officer, Ward 2(2), Hubballi. … Appellant Vs. M/s.KVG Bank Employees Co-operative Credit Co-op Society Ltd., Shankar Plaza, 2nd Floor, Dharwad. … Respondent PAN: AAAAK 7950 N Appellant by : Shri M.K.Biju, JCIT(DR) Respondent by : Shri Balram Rao, Advocate. Date of hearing : 08/11/2017 Date of pronouncement : 15/11/2017 O R D E R Per INTURI RAMA RAO, AM : This is an appeal filed by the revenue directed against the order of the Commissioner of Income-tax…

Income Tax Officer Ward-1, Bagalkot vs. Shri Bapooji Pattin Souhard Sahakari Niyamit, Bagalkot

ITA 827/BANG/2017[2013-14]Status: DisposedITAT Bangalore31 Oct 2017AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Laliet Kumarassessment Year : 2013-14

For Appellant: Shri B.R. Ramesh, Jt. CIT(DR)(ITAT) BengaluruFor Respondent: Shri Madhukar G. Hegde, CA
Section 143(3)Section 5Section 80PSection 80P(2)(a)Section 80P(4)

…free from tax notwithstanding that the conditions of another head of exemption are not satisfied and such income is not free from tax under that head of exemption...” 21) In the case of Commissioner of Income Tax v. Punjab State Co-operative Bank Ltd. (2008) 300 ITR 24 (Punjab & Haryana) = 2008-TIOL-337-HC-P-H-IT while dealing with an identical issue, the High Court of Punjab and Haryana held as follows: “ The provisions of section 80P were introduced with a view to encouraging and promoting the growth of the co- operative sector in the economic life of the country and in pursuance of the declared policy of the…

The Citizen Cooperative Society Ltd., Rep. by Managing Director G.Ranga Rao. Hyderabad vs. Asst. Commissioner of Income Tax

The appeal is dismissed in terms of the signed reportable

C.A. No.-010245-010245 - 2017Supreme Court08 Aug 2017
Section 2(19)Section 80PSection 80P(4)

…e of Commissioner of Income Tax v. Punjab State Co-operative Bank Ltd.6, while dealing with an identical issue, the High Court of Punjab and Haryana held as follows: “8. The provisions of section 80P were introduced with a view 5 (1998) 5 SCC 48 6 (2008) 300 ITR 24 (Punjab & Haryana H.C.) 18 to encouraging and promoting the growth of the co-operative sector in the economic life of the country and in pursuance of the declared policy of the Government. The different heads of exemption enumerated in the section are separate and distinct heads of exemption and are to be treated as such. Whenever a que…

ITO, Salem vs. S 9787 K.Kondappanaikenpatty Paccs Ltd., Salem

In the result, the appeals of the Revenue are dismissed

ITA 2342/CHNY/2015[2012-13]Status: DisposedITAT Chennai16 Mar 2016AY 2012-13

Bench: Shri A.Mohan Alankamony & Shri. G. Pavan Kumar

For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. A.V.Sreekanth, IRS, JCIT
Section 139Section 143(2)Section 260ASection 44ASection 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

…of the members in ‘A’ or ‘B’ category is concerned. We follow the same and accept contentions of the assessee”. 7. Similar issue had come up before the Hon’ble Punjab & Haryana High Court in the case of CIT Vs. Punjab State Cooperative Bank Ltd., reported as 300 ITR 24, wherein the Hon’ble High Court had decided the issue in favour of the assessee. The ld.DR has not been able to controvert the contentions of the AR. 8. The issue in appeal is similar to the one adjudicated by the co-ordinate bench in the case of M/s.SL(SPL) 151, Karkudalpatty Primary Agricultural Co-operative Credit Society Ltd., Vs. ITO (supra).…

ITO, Salem vs. S-681 Chinnathirupathi Paccs Ltd., Salem

In the result, the appeals of the Revenue are dismissed

ITA 2341/CHNY/2015[2012-13]Status: DisposedITAT Chennai16 Mar 2016AY 2012-13

Bench: Shri A.Mohan Alankamony & Shri. G. Pavan Kumar

For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. A.V.Sreekanth, IRS, JCIT
Section 139Section 143(2)Section 260ASection 44ASection 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

…of the members in ‘A’ or ‘B’ category is concerned. We follow the same and accept contentions of the assessee”. 7. Similar issue had come up before the Hon’ble Punjab & Haryana High Court in the case of CIT Vs. Punjab State Cooperative Bank Ltd., reported as 300 ITR 24, wherein the Hon’ble High Court had decided the issue in favour of the assessee. The ld.DR has not been able to controvert the contentions of the AR. 8. The issue in appeal is similar to the one adjudicated by the co-ordinate bench in the case of M/s.SL(SPL) 151, Karkudalpatty Primary Agricultural Co-operative Credit Society Ltd., Vs. ITO (supra).…

ITO, Salem vs. S-6608 Narasingapuram Primary Agricultural Co-Op Credit Society Ltd., Salem

In the result, the appeal of the Revenue is dismissed

ITA 1874/CHNY/2015[2007-08]Status: DisposedITAT Chennai09 Mar 2016AY 2007-08

Bench: Shri A.Mohan Alankamony & Shri. G. Pavan Kumar

For Appellant: Shri. M. Narayanan, Addl. CIT (Retd)
Section 143(1)Section 143(2)Section 143(3)Section 260ASection 80PSection 80P(4)

…(Appeals) has dealt on Co-ordinate Bench decision in detail at para no. 3 to 6 of the order and having satisfied with compliance of provisions of Sec. 80P of the Act relied Punjab and Haryana High Court decision in CIT vs. Punjab State Co-Operative Bank Ltd 300 ITR 24 and Co-ordinate bench decision in the case of M/s. SL(SPL) 151, Karkudalpatty Primary Agricultural Co-operative Credit Society Ltd vs. ITO in ITA No.292/Mds/2014, dated 17.03.2014. The ld. Commissioner of Income Tax (Appeals) on the basis of the submissions of ld. Authorised Representative and the orders of the Tribunal found the assessee soci…

ITO, Salem vs. S-1293 Tghammampatty Primary Agricultural Co-Op Credit Society Ltd, Salem

In the result, the appeal of the Revenue is dismissed

ITA 1241/CHNY/2015[2010-11]Status: DisposedITAT Chennai19 Aug 2015AY 2010-11

Bench: Shri Chandra Poojari & Shri V. Durga Raoआयकर अपील सं./Ita No.1241/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-11

For Appellant: Shri M. Narayanan, Retd. ACITFor Respondent: Dr. B. Nischal, JCIT
Section 2(16)Section 80Section 80PSection 80P(2)(a)

…/2013 members in ‘A’ or ‘B’ category is concerned. We follow the same and accept contentions of the assessee”. 7. Similar issue had come up before the Hon’ble Punjab & Haryana High Court in the case of CIT Vs. Punjab State Cooperative Bank Ltd., reported as 300 ITR 24, wherein the Hon’ble High Court had decided the issue in favour of the assessee. The ld.DR has not been able to controvert the contentions of the AR. 8. The issue in appeal is similar to the one adjudicated by the co-ordinate bench in the case of M/s.SL(SPL) 151, Karkudalpatty Primary Agricultural Co-operative Credit Society Ltd., Vs. ITO (supra)…

CIT v. Punjab State Cooperative Bank Ltd. (300 ITR 24) — Cited in 13 Judgments | BharatTax