Citizen Co-operative Society Ltd. v. ACIT

397 ITR 1Supreme Court of India2017#140 most cited

What is Citizen Co-operative Society Ltd. v. ACIT authority for?

A co-operative credit society engaged in banking business with the general public, accepting deposits from non-members and advancing loans to non-members, is treated as a co-operative bank. Such a society falls under the exclusionary clause of Section 80P(4) and is not eligible for deduction under Section 80P(2)(a)(i).

499

judgments rely on this decision, according to BharatTax’s citation analysis of 369,743 Indian tax judgments — from 2017 to 2026.

Also referred to as

Citizen Co-operative Society Ltd. v. ACIT · Section 80P(4) exclusion · co-operative bank definition · co-operative society banking business · deduction for co-operative banks · loans to non-members · deposits from public · 80P(2)(a)(i) eligibility · co-operative credit society deduction

Also reported as

84 Taxmann.com 114

Sections most often in play

Section 80P(2)(a)(i)Section 80P(2)(d)Section 143(3)Section 80PSection 80P(4)Section 56Section 250Section 2(19)

Issues it is cited on

section 59(2)section 2(n)section 80p(2)(a)(iii)section 5(b)section 58section 59section 80p(1)section 80p(4)section 80p(2)(a)section 80p(2)(a)(i)section 80p(2)section 2(19)

Judgments citing Citizen Co-operative Society Ltd. v. ACIT

The Kumbadaje Service Co Operative Bank Limited 383 Movvar, Kumbdaje vs. Income Tax Officer, Ward- 1 Kasaragod, Kasaragod

ITA 392/COCH/2024[2017-18]Status: DisposedITAT Cochin07 Nov 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Suresh Kumar Varma, CAFor Respondent: Smt.V.Swarnalatha, Sr.DR
Section 80P

…these assessment years for the sole reason that it had derived the corresponding interest income from regular members having voting rights as well as nominal/associate members and therefore, going by case law Citizen Cooperative Society Ltd., vs. ACIT [2017] 397 ITR 1 (SC) that it is only the interest income derived from extending credit facilities for the former category which qualifies for sec.80P relief. 3. Faced with this situation, learned DR could hardly dispute the clinching legal developments and their lordships’ latter decision in Mavilayi Service Cooperative Bank Ltd., vs. CIT [2021] 431 ITR 1 (SC) ha…

The Kumbadaje Service Co Operative Bank Limited 383 Movvar, Movvar vs. Income Tax Officer, Wqard-1, Kasaragod

ITA 388/COCH/2024[2016-17]Status: DisposedITAT Cochin07 Nov 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Suresh Kumar Varma, CAFor Respondent: Smt.V.Swarnalatha, Sr.DR
Section 80P

…these assessment years for the sole reason that it had derived the corresponding interest income from regular members having voting rights as well as nominal/associate members and therefore, going by case law Citizen Cooperative Society Ltd., vs. ACIT [2017] 397 ITR 1 (SC) that it is only the interest income derived from extending credit facilities for the former category which qualifies for sec.80P relief. 3. Faced with this situation, learned DR could hardly dispute the clinching legal developments and their lordships’ latter decision in Mavilayi Service Cooperative Bank Ltd., vs. CIT [2021] 431 ITR 1 (SC) ha…

The Kumbadaje Service Co Operative Bank Limited 383 Movvar, Movvar vs. Income Tax Officer, Ward-1 Kasaragod, Kasaragod

ITA 385/COCH/2024[2015-16]Status: DisposedITAT Cochin07 Nov 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Suresh Kumar Varma, CAFor Respondent: Smt.V.Swarnalatha, Sr.DR
Section 80P

…these assessment years for the sole reason that it had derived the corresponding interest income from regular members having voting rights as well as nominal/associate members and therefore, going by case law Citizen Cooperative Society Ltd., vs. ACIT [2017] 397 ITR 1 (SC) that it is only the interest income derived from extending credit facilities for the former category which qualifies for sec.80P relief. 3. Faced with this situation, learned DR could hardly dispute the clinching legal developments and their lordships’ latter decision in Mavilayi Service Cooperative Bank Ltd., vs. CIT [2021] 431 ITR 1 (SC) ha…

Karassery Service Co-Op Bank Ltd, Kozhikode vs. The ITO Ward 2(3), Kozhikode

ITA 427/COCH/2023[2017-18]Status: DisposedITAT Cochin06 Nov 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: --- None---For Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI AMARJIT SINGH, ACCOUNTANT MEMBER ITA No.426/Coch/2023 - Asst.Year 2015-2016 ITA No.427/Coch/2023 - Asst.Year 2015-2016 Karassery Service Co-operative Bank Limited, vs. The Income Tax Officer Mukkam Ward 2(3) Kozhikode – 673 602. Kozhikode. PAN AACAK0055A (Appellant) (Respondent) Appellant by : --- None--- Respondent by : Sri.Sanjit Kumar Das, CIT-DR Date of Pronouncement : 06.11.2024 Date of Hearing : 13.08.2024 ORDER PER BENCH : These twin assessee’s appeals in ITA Nos.426/Coch/2023 and 427/Coch…

Karassery Service Co-Op Bank Ltd, Kozhikode vs. The ITO Ward 2(3), Kozhikode

ITA 426/COCH/2023[2015-16]Status: DisposedITAT Cochin06 Nov 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: --- None---For Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI AMARJIT SINGH, ACCOUNTANT MEMBER ITA No.426/Coch/2023 - Asst.Year 2015-2016 ITA No.427/Coch/2023 - Asst.Year 2015-2016 Karassery Service Co-operative Bank Limited, vs. The Income Tax Officer Mukkam Ward 2(3) Kozhikode – 673 602. Kozhikode. PAN AACAK0055A (Appellant) (Respondent) Appellant by : --- None--- Respondent by : Sri.Sanjit Kumar Das, CIT-DR Date of Pronouncement : 06.11.2024 Date of Hearing : 13.08.2024 ORDER PER BENCH : These twin assessee’s appeals in ITA Nos.426/Coch/2023 and 427/Coch…

M/S the Kalanad Service Co-Operative Bank Ltd., Kasaragod vs. ITO Ward 1 & Tps, Kasaragod

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

ITA 681/COCH/2022[2017-2018]Status: DisposedITAT Cochin30 Oct 2024AY 2017-2018

Bench: Shri Inturi Rama Rao

For Appellant: Shri Arun Raj S., AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 80PSection 80P(2)(a)

…tive society, as it also provides credit facilities to nominal members who are classified as class C and class D members and placing reliance on the decision of the Hon'ble Supreme Court in the case of The Citizen Co-operative Society Ltd. v. Asst. CIT [2017] 397 ITR 1 (SC). 5. Being aggrieved, an appeal was filed before the CIT(A) who vide the impugned order confirmed the action of the AO. 6. Being aggrieved, the assessee is in appeal before the Tribunal. The solitary issue that arises in both the appeals is where the lower authorities were justified in denying deduction u/s. 80P(2)(a)(i) of the Act solely on…

M/S the Kalanad Service Co-Operative Bank Ltd., Kasaragod vs. ITO Ward 1 & Tps, Kasaragod

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

ITA 680/COCH/2022[2016-2017]Status: DisposedITAT Cochin30 Oct 2024AY 2016-2017

Bench: Shri Inturi Rama Rao

For Appellant: Shri Arun Raj S., AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 80PSection 80P(2)(a)

…tive society, as it also provides credit facilities to nominal members who are classified as class C and class D members and placing reliance on the decision of the Hon'ble Supreme Court in the case of The Citizen Co-operative Society Ltd. v. Asst. CIT [2017] 397 ITR 1 (SC). 5. Being aggrieved, an appeal was filed before the CIT(A) who vide the impugned order confirmed the action of the AO. 6. Being aggrieved, the assessee is in appeal before the Tribunal. The solitary issue that arises in both the appeals is where the lower authorities were justified in denying deduction u/s. 80P(2)(a)(i) of the Act solely on…

Chakkittapara Service Co-Operative Bank Ltd, Chakkittapara vs. ITO, Ward-2(1), Kozhikode

ITA 84/COCH/2024[2020-2021]Status: DisposedITAT Cochin23 Oct 2024AY 2020-2021

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri T.P. Paul, CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…ee’s section 80P claim deduction(s) pertaining to its interest income derived from nominal/associate members and deposits made in co-operative bank u/s. 80P(4) of the Act; involving varying sums by quoting case law Citizen Co- op Society Ltd., vs. ACIT [2017] 397 ITR 1 (SC); Totgar’s Co-operative Sale Society Ltd. v. ITO [2010] 322 ITR 283 (SC); respectively. 3. Learned CIT-DR’s foremost argument seeking to draw a distinction between assessee’s nominal/associate vis-à-vis regular members hardly deserves to be accepted in light of case law Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC) holdi…

Chakkittapara Service Co-Operative Bank Ltd, Chakkittapara vs. ITO, Ward-2(1), Kozhikode

ITA 83/COCH/2024[2018-2019]Status: DisposedITAT Cochin23 Oct 2024AY 2018-2019

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri T.P. Paul, CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…ee’s section 80P claim deduction(s) pertaining to its interest income derived from nominal/associate members and deposits made in co-operative bank u/s. 80P(4) of the Act; involving varying sums by quoting case law Citizen Co- op Society Ltd., vs. ACIT [2017] 397 ITR 1 (SC); Totgar’s Co-operative Sale Society Ltd. v. ITO [2010] 322 ITR 283 (SC); respectively. 3. Learned CIT-DR’s foremost argument seeking to draw a distinction between assessee’s nominal/associate vis-à-vis regular members hardly deserves to be accepted in light of case law Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC) holdi…

Chakkittapara Service Co-Operative Bank, Chakkittapara vs. ITO, Ward-2(1), Kozhikode

ITA 82/COCH/2024[2017-2018]Status: DisposedITAT Cochin23 Oct 2024AY 2017-2018

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri T.P. Paul, CAFor Respondent: Dr. S. Pandian, CIT-DR
Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…ee’s section 80P claim deduction(s) pertaining to its interest income derived from nominal/associate members and deposits made in co-operative bank u/s. 80P(4) of the Act; involving varying sums by quoting case law Citizen Co- op Society Ltd., vs. ACIT [2017] 397 ITR 1 (SC); Totgar’s Co-operative Sale Society Ltd. v. ITO [2010] 322 ITR 283 (SC); respectively. 3. Learned CIT-DR’s foremost argument seeking to draw a distinction between assessee’s nominal/associate vis-à-vis regular members hardly deserves to be accepted in light of case law Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC) holdi…

M/S. Shri Saraswathi Credit Souharda Sahakari Sangha Limited, Puttur vs. Income Tax Officer, Ward-1, Puttur

ITA 1729/BANG/2024[2018-19]Status: DisposedITAT Bangalore23 Oct 2024AY 2018-19

Bench: Ms. Padmavathy S. & Shri Prakash Chand Yadavshri Saraswathi Credit

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Ms. Neha Sahay, JCIT-DR
Section 234Section 57Section 80PSection 80P(2)(a)

…of the appellant's case. 2.1 The learned CIT[A] is further not justified in observing that the appellant being a Souharda is not a Co-operative Society and that the decision of the Hon'ble Supreme Court in the case of CITIZEN CO-OPERATIVE SOCIETY reported in 397 ITR 1 is applicable to the case of the appellant while upholding the denial of deduction claimed u/s.80P[2][a][i] of the Act without appreciating that the said judgement was explained in the later decision of the Hon'ble Supreme Court in the case of Mavilayi Service Co-operative Bank reported in 431 ITR 1 and therefore, the appellant ought to have been a…

Charkop Lands End Cooperative Housing Society Ltd, Kandivali West Mumbai vs. ITO, Kautilya Bhavan, Bkc, Mumbai

In the result, the assessee’s appeal is allowed

ITA 2843/MUM/2024[2020-2021]Status: DisposedITAT Mumbai15 Oct 2024AY 2020-2021

Bench: SHRI OM PRAKASH KANT (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(1)Section 2(19)Section 250Section 5Section 80PSection 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘H(SMC)’ BENCH MUMBAI BEFORE: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER Charkop Lands End Vs. ITO, Co-operative Kautilya Bhavan, BKC, Housing Society Ltd. Mumbai. Plot No. 23, Lands End Chs, Netaji Subhashchandra Bose Marg, Sector 2A, Charkop, Kandivali West, 400067. PAN/GIR No. AAAAC4607J (Appellant) .. (Respondent) Assessee by Shri. Siddharth Sunil Bhandari, ACA Revenue by Shri. Asif Karmali, Sr. DR Date of Hearing 30/07/2024 Date of Pronouncement 15/10/2024 आदेश / O R D E R PER SUNIL KUMAR SINGH (J.M): 1. This appeal has been p…

Stella Maris Co-Operative Housing Society Ltd, Mumbai vs. Income Tax Officer Ward 22(3)(6)(, Mumbai

In the result, the assessee’s appeal is allowed

ITA 1762/MUM/2024[2015-16]Status: DisposedITAT Mumbai15 Oct 2024AY 2015-16

Bench: SHRI BR BASKARAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(1)Section 2(19)Section 250Section 5Section 80PSection 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘J(SMC)’ BENCH MUMBAI BEFORE: SHRI BR BASKARAN, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER Stella Maris Co- Vs. Income Tax Officer Ward operative Housing 22(3)(6) Society Ltd. Piramal Chambers Lal Sitaladevi Temple Baug, Parel-400012, Road, Mahim, 400016. Mumbai-400016. PAN/GIR No. AADAS1717Q (Appellant) .. (Respondent) Assessee by Shri. Ajay Arvind Wadke Revenue by Shri. Ajit Pal Singh Daia (Sr. AR) Date of Hearing 18/07/2024 Date of Pronouncement 15/10/2024 आदेश / O R D E R PER SUNIL KUMAR SINGH (J.M): 1. This appeal has been preferred against the im…

Enayetpur S K U S Ltd., Malda vs. A.C.I.T., Circle - 3(1), Kolkata, Malda

ITA 713/KOL/2022[2017-2018]Status: DisposedITAT Kolkata30 Sept 2024AY 2017-2018

Bench: Shri Sanjay Gargandshri Sanjay Awasthi

Section 250Section 68Section 80Section 80P

…has failed to give the specific details of financials, members wise and non members wise and further has not confirmed that the transactions are not done with non-members. 3.9 The Hon’ble Supreme Court in the case of The Citizen Co-operative Society Limited 397 ITR 1 (SC) has held that “the assessee was engaged in the activity of granting loans to members of the general public as well and this was done without approval from…

M/S the General Insurance Employees Co-Operative Society Limited, Ernakulam vs. ITO, Non Corporate Ward 1 (5), Kochi

In the result, the appeal filed by the assessee is allowed for statistical purposes and the stay petition is dismissed as rendered infructuous

ITA 217/COCH/2024[AY 2017-2018]Status: DisposedITAT Cochin30 Sept 2024

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Respondent: Smt.Girly Albert, Sr.DR
Section 80Section 80P

…rs 2 ITA No.217/Coch/2024 & SA19/.Coch/2024. The General Insurance Employees co-op So.Ltd. by providing credit facilities. The Assessing Officer relied on the judgment of the Hon’ble Supreme Court in The Citizen Co- operative Society Ltd. v. ACIT reported in 397 ITR 1 (SC) and the full bench judgment of the Hon’ble Kerala High Court in the case of CIT v. Mavilayi Service Co-operative Bank Ltd. [2019] 414 ITR 67 (FB) (Ker.) had disallowed the deduction claimed u/s 80P of the Act. As against the said order the assessee filed an appeal before the ld.CIT(A) and contended that the Hon’ble Supreme Court in the case of…

Vadakkevila Service Co-Operative Bank Ltd, Kollam vs. The ITO, Kollam

Appeal is allowed in above terms

ITA 478/COCH/2023[2017-18]Status: DisposedITAT Cochin25 Sept 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Ms.Anoopa, AdvocateFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 194ASection 40Section 56Section 80PSection 80P(2)Section 80P(2)(a)

…s a fit instance to hold that the same indeed is eligible to claim sec.80P(2)(a)(i) deduction. The assessee’s fourth substantive ground is accepted accordingly. 7. Learned CIT-DR further submits in light of Citizen Co- operative Society Ltd., vs. ACIT (2017) 9 SCC 364 that the assessee has derived its interest income from non-member and therefore, the impugned disallowance deserves to be confirmed u/s.80P of the Act. We are of the considered view that their lordships’ foregoing decision stand distinguished in assessee’s favour in Mavilayi Service Co-operative Bank Ltd., v. CIT (2021) 431 ITR 1 (SC) and therefore…

Murude Sahakari Patsanstha Maryadit, Mumbai vs. ITO, Ward-22(2)(1), Mumbai

The Appeal is allowed

ITA 901/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Sept 2024AY 2018-19

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dharan GandhiFor Respondent: Shri Himanshu Sharma
Section 143Section 143(3)Section 5Section 80Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…on 80P(2)(d) of the Act the Assessing Officer had placed reliance on the provisions contained in Section 80P(4) of the Act, the judgment of the Hon’ble Supreme Court in the case of Citizen Co-operative Society Limited Vs ACIT : Circle- 9(1), Hyderabad: [2017] 397 ITR 1 (SC) and the judgment of the Hon’ble Karnataka High Court in the case of Pr.CIT vs. Totgars Co-operative Sale Society Ltd.: 2017 395 ITR 611 (Kar). In the case of Mavilayi Services Co-operative Bank Limited Vs. CIT, Calicut: [2021] 431 ITR 1 (SC) [12/01/2021], the Hon’ble Supreme Court had, after taking into consideration the aforesaid provisions o…

Income Tax Officer, Income Tax Mumbai vs. State Bank of India Employees M.S. Patel Co-Op Credit Society Ltd, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 3995/MUM/2023[2016-17]Status: DisposedITAT Mumbai23 Sept 2024AY 2016-17

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Shri Hemant ShahFor Respondent: Smt. Smiti Samant, CIT, DR
Section 194ASection 194A(3)(V)Section 56Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)Section 8O

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “G”, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.3995/Mum/2023 Assessment Year: 2016-17 Income Tax Officer, Ward-26(2)(1), Mumbai VS State Bank of India Employees M.S. Patel Co-op Credit Society Ltd. 3rd Floor, State Bank Building, SBI Mumbai Main Branch, Samachar Marg, Near Horniman Circle, Fort, Mumbai-400023. PAN:AAAAS 9621 A (Respondent) (Appellant) Present for: Assessee by : Shri Hemant Shah Revenue by : Smt. Smiti Samant, CIT, DR Date of Hearing : 11.07.2024 Date of Pronouncement : 23.09.2024 ORDER P…

M/S Ijmima Imitation Jewellery Market Society Limited, Mumbai vs. AO Circle 41(3)(1), Mumbai

ITA 1618/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Sept 2024AY 2018-19
Section 143(2)Section 2(19)Section 250Section 5Section 80PSection 80P(2)(d)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI BR BASKARAN, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ITA No. 1618/MUM/2024 (Assessment Year : 2018-19) M/s Ijmima Imitation Jewellery Vs. AO, Circle 41(3)(1) Kautilya Bhavan, Market Society Mumbai-400051. Limited Society Office Ijmima Complex, Raheja Metroplex, Link Road, Malad(W), Mumbai-400064. PAN/GIR No. AAAA16896F (Appellant) (Respondent) Assessee by Shri. Aajay Singh Revenue by Shri. H.M. Bhatt (Sr. DR) Date of Hearing 20/06/2024 Date of Pronouncement 19/09/2024 आदेश / ORDER PER SUNIL KUMAR SINGH (J.M): 1. This appeal…

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)

…xus with the contributors and participators is solely missing. Thereafter, the Assessing Officer held that the facts involved in the assessee's case are similar to the case of Citizen Co-operative Society Ltd [Civil Appeal No. 10245 of 2017 reported in (2017) 397 ITR 1] and applying the ratio of the Hon'ble Apex Court disallowed the deduction claimed u/s 80P. 6.1 The Hon'ble Supreme Court in the case of Mavilayi Service Co-Operative Bank Ltd Vs Commissioner Of Income Tax (2021) 431 ITR 1 (SC) dated 12.01.2021 while confirming its own judgment in the case of Citizen Co-operative Society Limited Vs Assistant Commi…