How many judgments cite Citizen Co-operative Society Ltd. v. ACIT?

499 judgments on BharatTax cite Citizen Co-operative Society Ltd. v. ACIT (397 ITR 1), spanning 2017 to 2026.

Which sections of the Income Tax Act does Citizen Co-operative Society Ltd. v. ACIT come up under?

It is most often cited in judgments turning on Section 80P(2)(a)(i), Section 80P(2)(d), Section 143(3), Section 80P, Section 80P(4), Section 56.

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 370,744 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 80P Section 80P(4)Section 56 Section 250 Section 2(19)

Issues it is cited on

section 59(2)section 2(n)section 80p(2)(a)(iii)section 5(b)section 58 section 59 section 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

Kuvempu Co Operative Credit Society, Bangalore vs. Income Tax Officer, Ward-2(2)(2), Bangalore

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

ITA 229/BANG/2024[2020-21]Status: DisposedITAT Bangalore17 Apr 2024AY 2020-21

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. Girish T. L, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bengaluru

Section 143(3)Section 18Section 18(2)Section 20Section 250Section 80PSection 80P(2)(a)

…assessee was dealing with nominal / associate members who are non-members and hence lost the concept of mutuality. In holding so, the AO relied on the judgment of Hon'ble Apex Court in the case of Citizen Co-operative Society Ltd., Vs. ACIT reported in (2017) 397 ITR 1. 4. Aggrieved by the Order of the AO denying the claim of deduction under section 80P(2)(a)(i) of the Act, assessee preferred appeal before the First Appellate Authority (FAA). The CIT(A) confirmed the view taken by the AO. The relevant finding of the CIT(A) reads as follows: “5.2 The addition made by the Assessing Officer and submissions of the ap…

Maharashtra Nagri Co Op Credit Society Ltd, Hinghanghat vs. ITO, Ward-1, Wardha

Appeal is allowed in above terms

ITA 52/NAG/2023[2017-18]Status: DisposedITAT Nagpur16 Apr 2024AY 2017-18

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Mahavir Atal, C.AFor Respondent: Shri Abhay Y. Marathe

Section 139(1)Section 142(1)Section 144Section 80ASection 80A(5)Section 80P(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR “SMC” BENCH :NAGPUR [VIRTUAL HEARING] BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER I.T.A.No.52/NAG./2023 Assessment Year 2017-2018 Maharashtra Nagari Co-op Credit Society Ltd., 105, The Income Tax Officer, Seva Samiti Bldg Market, Ward-1, Main Road, Indira Gandhi Aayakar Bhavan, Civil Lines, vs. Chowk, Hinghanghat. Wardha – 442 001. PIN - 442 301. Maharashtra Maharashtra. PAN AAAAM4597P (Appellant) (Respondent) For Assessee : Shri Mahavir Atal, C.A. For Revenue : Shri Abhay Y. Marathe Date of Hearing : 22.03.2024 Date of Pronouncement : 16.04.2024 ORDER This asses…

M/S. Kajekar Seva Shakari Bank, Bantwal vs. Income-Tax Officer, Ward-2(3), Mangaluru

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

ITA 244/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Apr 2024AY 2017-18

Bench: Shri George George Kshri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Department

Section 142(1)Section 144Section 80Section 80PSection 80P(2)Section 80P(2)(a)

…sessee of Rs.4,01,705/- and the income from principal business is Rs.22,32,033/- to which, the assessee claimed deduction. The AO after relying on the judgment of Hon’ble Apex Court Page 3 of 6 in the case of M/s Citizen Co-operative Society Ltd. reported in 397 ITR 1, noted that the assessee has failed the principle of mutuality and he also referred to the provision of Karnataka Co-operative Society Act 1959. 5. Aggrieved, the assessee field appeal before the CIT(A). 6. The CIT(A) issued various notices on different dates. However, the assessee did not respond to any of the notices, therefore, the CIT(A) also…

The Vallapuzha Service Co-Op Bank Ltd, Palakkad vs. The ITO Ward 3, Palakkad

ITA 328/COCH/2023[2013-14]Status: DisposedITAT Cochin26 Mar 2024AY 2013-14

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri V.P. Narayanan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R

Section 143(3)Section 80PSection 80P(1)

…nition and, two, is a cooperative bank, i.e., a cooperative society in the business of banking, even as clarified by the Hon'ble Courts time and again, as in Mavilayi SCB Ltd. v. CIT [2021] 431 ITR 1 (SC); Citizen Cooperative Society Ltd. v. Assst. CIT [2017] 397 ITR 1 (SC); Pr. CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker); Mohammed Usman v.…

The Vallapuzha Service Co-Op Bank Ltd, Palakkad vs. The ITO Ward 3, Palakkad

ITA 327/COCH/2023[2012-13]Status: DisposedITAT Cochin26 Mar 2024AY 2012-13

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri V.P. Narayanan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R

Section 143(3)Section 80PSection 80P(1)

M/S. Hassan City House Building Co-Operative Society, Hassan vs. Income Tax Officer, Ward-1 & Tps, Hassan

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

ITA 27/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 Mar 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18

For Appellant: Ms. Sunaina Bhatia, CA

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

…ot exist, as the interest income has been earned by the assessee by providing credit facility to its both members and non- members. The Ld.AO thus relying on the decision of Hon’ble Supreme Court in case of Citizen Co-operative Society Ltd. reported in (2017) 397 ITR 1 disallowed the deduction claimed by the assessee u/s. 80P(2)(a)(i) amounting to Rs.47,67,759/-. Page 4 of 6 2.3 Aggrieved by the order of the Ld.AO, assessee preferred appeal before the Ld.CIT(A). 2.4 Before the Ld.CIT(A), the assessee relied on various decisions including the decision of Hon’ble Supreme Court in case of Mavilayi Service Co- oper…

Kanak Pattin Sahakari Sangh Niyiamit, Bilagi vs. Income-Tax Officer, Ward-1 & Tps, Bagalkot

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

ITA 851/BANG/2023[2020-21]Status: DisposedITAT Bangalore22 Mar 2024AY 2020-21

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2020-21

For Appellant: Shri Prasanna .N Urala, Advocate

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

…ot exist, as the interest income has been earned by the assessee by providing credit facility to its both members and non- members. The Ld.AO thus relying on the decision of Hon’ble Supreme Court in case of Citizen Co-operative Society Ltd. reported in (2017) 397 ITR 1 disallowed the deduction claimed by the assessee u/s. 80P(2)(a)(i) amounting to Rs. 17,50,465/-. 2.3 Aggrieved by the order of the Ld.AO, assessee preferred appeal before the Ld.CIT(A). 2.4 Before the Ld.CIT(A), the assessee relied on various decisions including the decision of Hon’ble Supreme Court in case of Mavilayi Service Co- operative Bank…

M/S. Swamy Vivekananda Co-Operative Society Limited, Tumakuru vs. Income Tax Officer, Ward-3, Tumkur

ITA 1095/BANG/2023[2018-19]Status: DisposedITAT Bangalore22 Mar 2024AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Ms. Sunaina Bhatia, CAFor Respondent: Dr. Nischal, Addl. CIT (DR)

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

…ce Co-operative Bank Ltd. v. CIT reported in 431 ITR 1 has not distinguished between the nominal members and associate members. Further he submitted that Hon'ble Supreme Court has distinguished the facts of Citizen Co-operative Society Ltd. reported in (2017) 397 ITR 1 wherein the issue was pertaining to the provisions of section 80P(2). 5. On the contrary, the Ld.DR relied on the orders passed by authorities below. We have perused the submissions advanced by both sides in the light of records placed before us. 6. Before us, the Ld.AR submitted that there is a delay of 89 days in filing the present appeals before…

M/S. Swamy Vivekananda Co-Operative Society Limited, Tumakuru vs. Income Tax Office, Ward-3, Tumkur

ITA 1094/BANG/2023[2017-18]Status: DisposedITAT Bangalore22 Mar 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Ms. Sunaina Bhatia, CAFor Respondent: Dr. Nischal, Addl. CIT (DR)

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

…e Co- operative Bank Ltd. v. CIT reported in 431 ITR 1 has not distinguished between the nominal members and associate members. Further he submitted that Hon'ble Supreme Court has distinguished the facts of Citizen Co-operative Society Ltd. reported in (2017) 397 ITR 1 wherein the issue was pertaining to the provisions of section 80P(2). 5. On the contrary, the Ld.DR relied on the orders passed by authorities below. We have perused the submissions advanced by both sides in the light of records placed before us. 6. Before us, the Ld.AR submitted that there is a delay of 89 days in filing the present appeals before…

Reserve Bank Cooperative Society Ltd., Jaipur vs. ITO, Ward-6(2), Jaipur

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

ITA 10/JPR/2024[2020-21]Status: DisposedITAT Jaipur05 Mar 2024AY 2020-21

Bench: Sh. Sandep Gosain & Dr. M. L. Meena

For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. A. S. Nehra, Addl. CIT

Section 56Section 80PSection 80P(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCHES, “A”JAIPUR BEFORE SH. SANDEP GOSAIN, JUDICIAL MEMBER AND DR. M. L. MEENA, ACCOUNTANT MEMBER I.T.A. No. 10/JPR/2024 Assessment Year: 2020-21 Reserve Bank Cooperative Vs. Income Tax Officer, Society Ltd., C/o RBI Building, Ward -6(2), Jaipur Rambagh Circle, Tonk Road, Jaipur 302015, Raj. [PAN:AAATR5829A] (Respondent) (Appellant Appellant by : Sh. P. C. Parwal, C.A. Respondent by : Sh. A. S. Nehra, Addl. CIT Date of Hearing : 14.02.2024 Date of Pronouncement : 05.03.2024 ORDER Per Dr. M. L. Meena, AM: The captioned appeal has been filed by the assessee agai…

Anugraha Vividhoddesha Sahakari Sangha, Belthangady vs. Income Tax Officer, Ward-1, Puttur

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

ITA 219/BANG/2024[2017-18]Status: DisposedITAT Bangalore05 Mar 2024AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Sandeep Singh Karhailassessment Year : 2017-18

For Appellant: Smt. Pratibha R, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 18Section 80P(2)(a)

…f the Karnataka co- operative societies’ Act 1959 as well as violation of the principles of mutuality. The AO also relied on the judgments of Hon’ble Apex Court in the case of Citizen Co- operative Society Ltd., [Civil Appeal No.10245/2017] reported in [2017] 397 ITR 1. As per the judgment of Hon’ble Apex Court, the assessee is not eligible for claim of deduction u/s 80P(2)(a)(i) of the Act and he also noted that the assessee is also not eligible for claim of deduction u/s Page 4 of 6 80P(2)(d) of the Act relying on the recent judgment of Hon’ble Jurisdictional High Court in the case of Totgar Co- operative Sale…

M/S. Primary Agricultural Credit Co-Operative Society Ltd Guruvayanakere, Belthangady vs. Income-Tax Officer, Ward-1, Puttur

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

ITA 1006/BANG/2023[2017-18]Status: DisposedITAT Bangalore06 Feb 2024AY 2017-18

Bench: Shri George George K & Shri Chandra Poojariassessment Year : 2017-18 M/S. Primary Agricultural Credit Vs. Ito, Co-Operative Society Ltd., Ward –1, 1 ‘Jeshta’ Uppinangady Road, Puttur. Guruvayanakere, Belthangady – 574 217. Pan : Aabas 3237 K Appellant Respondent Assessee By : Ms. Harsha J, Advocate Revenue By : Shri. Parithivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 06.02.2024 Date Of Pronouncement : 06.02.2024

For Appellant: Ms. Harsha J, AdvocateFor Respondent: Shri. Parithivel, JCIT(DR)(ITAT), Bengaluru

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

…der dated 04.10.2019. In the assessment completed under section 143(3) of the Act, the AO denied the claim under section 80P of the Act. The AO relying on the judgment of Hon’ble Apex Court in the case of Citizen Co- operative Society Ltd., reported in (2017) 397 ITR 1, held that assessee was primarily dealing with non-members, hence, had violated the principles of mutuality. The AO also observed that assessee had earned interest income from Co-operative Bank and same is to be assessed under section 56 of the Act. The AO relying on the judgment of the Hon’ble Apex Court in the case of Totgar’s Co-operative Sales…

Jafari Momin Vikas Co-Op. Credit Society Ltd., Patan vs. The Income Tax Officer, Ward-4 Present Ward-1, Patan

Appeal of the assessee is allowed

ITA 279/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad19 Jan 2024AY 2018-19

Bench: Ms. Suchitra R. Kambleassessment Year: 2018-19 Jafari Momin Vikas Co-Op. Credit Vs Income Tax Officer, Society Limited, Ward-4 At & Post Kakoshi, Tal. Siddhpur, Dist. (Present Ward-1), Patan, Kakoshi, Gujarat Patan Pan : Aaaaj 1053 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Hasmukh V. Doshi & Shri Mehal H. Doshi, Ars Revenue By : Shri Purushottam Kumar, Sr Dr सुनवाई की तारीख/Date Of Hearing : 08/01/2024 घोषणा की तारीख /Date Of Pronouncement : 19/01/2024

For Appellant: Shri Hasmukh V. Doshi &For Respondent: Shri Purushottam Kumar, Sr DR

Section 250Section 40A(7)Section 40A(9)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, AHMEDABAD \ BEFORE Ms. SUCHITRA R. KAMBLE, JUDICIAL MEMBER Assessment Year: 2018-19 Jafari Momin Vikas Co-op. Credit Vs Income Tax Officer, Society Limited, Ward-4 At & Post Kakoshi, Tal. Siddhpur, Dist. (Present Ward-1), Patan, Kakoshi, Gujarat Patan PAN : AAAAJ 1053 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Hasmukh V. Doshi & Shri Mehal H. Doshi, ARs Revenue by : Shri Purushottam Kumar, Sr DR सुनवाई की तारीख/Date of Hearing : 08/01/2024 घोषणा की तारीख /Date of Pronouncement : 19/01/2024 O R D E R This appeal filed by the assessee is direct…

M/S. Ubaradka Mithur Primary Agricultural Credit Co-Operative Society Ltd., Sullia vs. Income-Tax Officer, Ward-1, Puttur

ITA 1015/BANG/2023[2017-18]Status: DisposedITAT Bangalore19 Jan 2024AY 2017-18

Bench: Shri Chandra Poojari & Ms. Madhumita Roy

Section 143(1)Section 143(2)Section 143(3)Section 80PSection 80P(1)Section 80P(2)(d)Section 8O

…owed to participate in the administration and they are not entitled to vote as particular category of member is not entitled to participate and thereby the ld. AO followed the decision of Hon'ble Supreme Court in the case of Citizen Co-operative Society Ltd. (397 ITR 1) (SC). However, we find that the decision of Hon'ble Supreme Court in the case of Mavilayi Service Cooperative Bank Ltd. & Ors. Vs. CIT (431 ITR 1) (SC), wherein held as under: “It is important to note that though the main object of the primary agricultural society in question is to provide financial assistance in the form of loans to its members f…

Town Vividoddesha Sahakari Bhandara Niyamitha, Tumkuru vs. Income Tax Officer, Ward-1 & Tps, Tumkur

In the result, the assessee’s appeal is allowed

ITA 1089/BANG/2023[2014-15]Status: DisposedITAT Bangalore17 Jan 2024AY 2014-15

Bench: Shri George George K. & Shri Chandra Poojariassessment Year : 2014-15

For Appellant: Shri Sandeep Chalapathy, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel

Section 143(2)Section 143(3)Section 154Section 154(3)Section 80P

…sment order completed is a mistake apparent from the record. The rectification order does not provide for any reason. The AO in the show cause notice had referred to the Hon’ble Apex Court judgment in the case of Citizen Co- operative society Ltd. reported in 397 ITR 1 (SC) where benefit of deduction u/s. 80P was denied since in the facts of that case assessee was dealing with non-members and had violated the principles of mutuality. The AO has also referred to the judgment of Hon'ble Supreme Court in the case of Sourashtra Kutch Stock Exchange Ltd. [2008] 305 ITR 227 / 173 Taxman 322 (SC) for the limited proposi…

M/S. Ampar Co-Operative Agriculture Society Limited, Udupi vs. Income-Tax Officer, Ward-1, Udupi

In the result, the appeals of the Assessee for AY 2013-14 & 2014-15 are allowed while the appeal for AY 2015-16 is partly allowed

ITA 796/BANG/2023[2020-21]Status: DisposedITAT Bangalore21 Dec 2023AY 2020-21

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

For Appellant: Shri Akshaya K.S., A.RFor Respondent: Dr. Nischal, D.R

Section 143(3)Section 43BSection 80PSection 80P(2)Section 80P(2)(a)

…ITA Nos.795 & 796/Bang/2023 M/s. Ampar Co-operative Agriculture Society Ltd., Udupi IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. MADHUMITA ROY, JUDICIAL MEMBER ITA Nos.795 & 796/Bang/2023 Assessment Years: 2017-18 & 2020-21 M/s. Ampar Co-operative Agriculture Society Ltd. ½ B1, AMPAR, Ampar B.O. Angalli ITO Vs. Udupi Ward-1 Karnataka 576 211 Udupi PAN NO : AADAA2045D APPELLANT RESPONDENT Assessee by : Shri Akshaya K.S., A.R. Revenue by : Dr. Nischal, D.R. Date of Hearing : 12.12.2023 Date of Pronouncement : 21.12.2023 O R D E R PER MAD…

M/S. Ampar Co-Operative Agriculture Society Limited, Udupi vs. Income-Tax Officer, Ward-1, Udupi

In the result, the appeals of the Assessee for AY 2013-14 & 2014-15 are allowed while the appeal for AY 2015-16 is partly allowed

ITA 795/BANG/2023[2017-18]Status: DisposedITAT Bangalore21 Dec 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

For Appellant: Shri Akshaya K.S., A.RFor Respondent: Dr. Nischal, D.R

Section 143(3)Section 43BSection 80PSection 80P(2)Section 80P(2)(a)

Bantwal Pubilc Employees Consumers Co- Operative Society, Bantwala vs. Income Tax Officer, Ward-2(3), Mangalore

In the result, appeal filed by the assessee is dismissed

ITA 903/BANG/2023[2017-18]Status: DisposedITAT Bangalore18 Dec 2023AY 2017-18

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2017-18 M/S. Bantwal Public Employees Consumers Vs. Ito, Co-Operative Society, Ward – 2(3), Kaikamba, Jodumarga, Bantwala – 574 219, Mangalore. Dakshina Kannada. Pan : Aabab 0979 P Appellant Respondent Assessee By : Shri. Sriram V. Roa, Ca Revenue By : Shri. Ganesh R Ghale, Standing Counsel For Revenue. Date Of Hearing : 18.12.2023 Date Of Pronouncement : 18.12.2023

For Appellant: Shri. Sriram V. Roa, CAFor Respondent: Shri. Ganesh R Ghale, Standing Counsel for Revenue

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

…AO denied the claim of deduction under section 80P of the Act. The AO held that assessee has not complied with the principle of mutuality and relied on the judgment of the Hon’ble Apex Court in the case of Citizen Co-operative Society Ltd., reported in (2017) 397 ITR 1. Further the AO held that the total amount claimed as deduction under section 80P of the Act is in respect of interest earned on deposit with Co-operative Banks and in view of the judgment of the Hon’ble jurisdictional High Court in the case of PCIT Vs. Totagars Co-operative Sale Society Ltd., reported in 395 ITR 611 (Karnataka), the assessee is no…

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

ITA 62/COCH/2023[2018-19]Status: DisposedITAT Cochin13 Dec 2023AY 2018-19

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

Section 143(3)Section 5Section 80PSection 80P(1)Section 80P(2)(a)

…e on demand or otherwise, and withdrawable by cheque, draft order or otherwise.’ Reliance for the purpose is placed, inter alia, on Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC); The Citizen Co-operative Society Ltd. v. Asst. CIT [2017] 397 ITR 1 (SC), as indeed Pr.CIT v. Poonjar Service Co-op. Bank Ltd. [2019] 414 ITR 67 (Ker)(FB).The only difference in the case of Vilavattam SCB Ltd. is that the ratio of agricultural advances is at a negligible 0.12%, and the claim for deduction is in entirety u/s. 80P(2)(a)(i). The matters were heard at length; the issue arising being principally legal.…

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

ITA 61/COCH/2023[2017-18]Status: DisposedITAT Cochin13 Dec 2023AY 2017-18

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

Section 143(3)Section 5Section 80PSection 80P(1)Section 80P(2)(a)