Kerala State Cooperative Agricultural and Rural Development Bank Ltd. v. Assessing Officer

Q: How many judgments cite Kerala State Cooperative Agricultural and Rural Development Bank Ltd. v. Assessing Officer?

93 judgments on BharatTax cite Kerala State Cooperative Agricultural and Rural Development Bank Ltd. v. Assessing Officer (458 ITR 384), spanning 2021 to 2026.

Q: Which sections of the Income Tax Act does Kerala State Cooperative Agricultural and Rural Development Bank Ltd. v. Assessing Officer come up under?

It is most often cited in judgments turning on Section 80P(2)(d), Section 80P(4), Section 80P(2)(a)(i), Section 250, Section 80P, Section 143(3).

458 ITR 384Supreme Court of India2023#1227 most cited

What is Kerala State Cooperative Agricultural and Rural Development Bank Ltd. v. Assessing Officer authority for?

Deduction under section 80P(2)(d) of the Income-tax Act is available to cooperative societies for interest income. This Supreme Court decision affirms that the legal controversy on this matter is settled.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2021 to 2026.

Also referred to as

Kerala State Cooperative Agricultural and Rural Development Bank Ltd. · Assessing Officer · Section 80P(2)(d) deduction · cooperative societies · interest income · tax exemption · inter-cooperative deposits · settled law · no more res integra · 2023 SC judgment

Also reported as

295 Taxmann 675

Sections most often in play

Section 80P(2)(d)Section 80P(4)Section 80P(2)(a)(i)Section 250 Section 80P Section 143(3)Section 143(1)Section 56

Issues it is cited on

section 2(u)section 56(cci)section 56(c)(i)(cci)section 56(c)section 2(d)section 5(c)section 22(1)(b)section 2(c)section 5(b)section 80(p)(4)section 22(1)section 80(p)(2)

Judgments citing Kerala State Cooperative Agricultural and Rural Development Bank Ltd. v. Assessing Officer

PREMIUM TOWER CO OPERATIVE HOUSING SOCIETY LTD ,MUMBAI vs. ITO WARD 24(3)(1), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 418/MUM/2026[2018-19]Status: DisposedITAT Mumbai10 Apr 2026AY 2018-19

For Appellant: Shri Rajesh ShahFor Respondent: Shri Pravin Salunkhe, (Sr. DR)

Section 139Section 143(1)Section 250Section 80P(2)(d)Section 80P(4)

…the facts of the instant case. 7. The respectful reliance is placed on the judgment passed by Hon'ble Apex Court in the case of Kerala State Cooperative Agricultural and Rural Development Bank Ltd v. Assessing Officer [2023] 154 taxmann.com 305/295 Taxman 675/458 ITR 384 (SC). The relevant extract is as follows- "28. Having heard learned advocates for the respective parties and considering the controversy arising in these tax appeals, we are of the opinion that the controversy sought to be canvassed with regard to deduction under section 80P(2)(d) of the Act is no more res integra in view of the decision of this…

MATRUCHHAYA COMMERCIAL PREMISES CO OP SOCIETY LIMITED,MUMBAI vs. INCOME TAX OFFICER, WARD 125(1), MUMBAI, AAYAKAR BHAVAN, M.K. ROAD

In the result, the appeal of the assessee bearing ITA No

ITA 9179/MUM/2025[2021-22]Status: DisposedITAT Mumbai13 Mar 2026AY 2021-22

Section 143(1)Section 154Section 250Section 80Section 80P(2)(d)Section 80P(4)

…ced on the\norder of PCIT Vs Annasaheb Patil Mathadi Kamgar Sahakari Pathpedi Limited,,\nreported in (2023) 150 taxmann.com 173 (SC) and Kerala State Co-Operative\nAgricultural And Rural Development Bank Ltd. KSCARDB vs. Assessing Officer,\nreported in [2023] 458 ITR 384 (SC) where the Hon'ble Apex Court categorically\nstated that cooperative bank is the cooperative society and not acted as Bank\nunder Banking Regulation Act,1949. We note the order of the coordinate bench of\nITAT in Kumkum Kavita Co-operative Housing Society Ltd (supra) has taken same\nview in favour of the assessee. So, the interest earned from…

MATRUCHHAYA COMMERCIAL PREMISES CO-OP SOCIETY LIMITED,MUMBAI vs. INCOME TAX OFFICER, WARD 125(1), MUMBAI, AAYAKAR BHAVAN, M.K. ROAD

In the result, the appeal of the assessee bearing ITA No

ITA 9178/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Section 143(1)Section 154Section 250Section 80Section 80P(2)(d)Section 80P(4)

…ced on the\norder of PCIT Vs Annasaheb Patil Mathadi Kamgar Sahakari Pathpedi Limited,,\nreported in (2023) 150 taxmann.com 173 (SC) and Kerala State Co-Operative\nAgricultural And Rural Development Bank Ltd. KSCARDB vs. Assessing Officer,\nreported in [2023] 458 ITR 384 (SC) where the Hon'ble Apex Court categorically\nstated that cooperative bank is the cooperative society and not acted as Bank\nunder Banking Regulation Act,1949. We note the order of the coordinate bench of\n\nITAT in Kumkum Kavita Co-operative Housing Society Ltd (supra) has taken same\nview in favour of the assessee. So, the interest earned fr…

PRIMARY COOPERATIVE AGRICULTURE RURAL DEVELOPMENT BANK LIMITED ,CHIKMAGALUR vs. INCOME TAX OFFICER, WARD-2, CHIKMAGALUR

In the result, the Appeal of the Assessee is allowed

ITA 1843/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18 M/S. Primary Cooperative Agriculture Rural Development Bank Limited, The Income Tax Officer, D. No. 22, Sharadha Nagar, Ward-2, Vs. Sringeri, Chikmagalur District, Chikmagalur. Karnataka – 577 139. Pan: Aacap9326R Appellant Respondent

For Appellant: Shri Prasanna Shenoy, CA

Section 143(3)Section 4Section 5BSection 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(4)Section 80P(4)(b)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘SMC’ BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE – PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER Assessment Year : 2017-18 M/s. Primary Cooperative Agriculture Rural Development Bank Limited, The Income Tax Officer, D. No. 22, Sharadha Nagar, Ward-2, Vs. Sringeri, Chikmagalur District, Chikmagalur. Karnataka – 577 139. PAN: AACAP9326R APPELLANT RESPONDENT Assessee by : Shri Prasanna Shenoy, CA : Shri Ganesh R Ghale – Advocate, Revenue by Standing Counsel for Revenue Date of Hearing : 03-12-2025 Date of Pronouncement : 09-02-2026 ORDER PER PRASHANT MAHARIS…

SREE MARUTHI CO-OPERATIVE HOUSING SOCIETY,BANGALORE, KARNATAKA vs. ITO WARD 7(2)(2), BANGALORE, BANGALORE, KARNATAKA

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

ITA 2164/BANG/2024[2017-18]Status: DisposedITAT Bangalore03 Feb 2026AY 2017-18

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

For Appellant: Shri P.R. Suresh, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…upreme Court reported in 431 ITR 1 in the case of Mavilayi Service Co-operative Bank Ltd. v. CIT and in the case of Kerala State Co-operative Agricultural and Rural Development Bank Ltd. KSCARDB v. the Assessing Officer, Trivandrum and Ors. reported in (2023) 458 ITR 384 wherein the Hon’ble Supreme Court has held that the co- operative banks are necessarily a species of the co- operative society. Therefore the interest income earned from the said investments with the other co-operative societies are eligible for deduction u/s. 80P(2)(d) of the Act. 9. Even though this issue was considered by the Single Member Ben…

MUDUR VYAVASAYA SEVA SAHAKARI SANGHA LTD vs. THE COMMISSIONER OF INCOME TAX APPEALS

ITA/56/2025HC Karnataka31 Jan 2026

Bench: S.G.PANDIT,K. V. ARAVIND

Section 260Section 260ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…eduction u/s. 80P(2)(a)(i) of the Act. (iv) Whether in the facts and circumstances of the case and in law, was it correct in holding that the ratio decidendi in Kerala State Co- operative Agricultural Rural Development Bank Ltd. vs. A.Ο., reported in 458 ITR 384 (SC) is squarely applicable to the appellant." - 4 - HC-KAR NC: 2026:KHC:6289-DB ITA No. 56 of 2025 4. The assessee filed its return of income for the Assessment Year 2017–18 claiming deduction under Section 80P of the Act, in respect of income derived from providing credit facilities to its nominal members, as well…

SREE MARUTHI COOPERATIVE HOUSING SOCIETY ,BENGALURU vs. INCOME TAX OFFICER, WARD-7(2)(3), BENGALURU

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

ITA 1895/BANG/2024[2016-17]Status: DisposedITAT Bangalore09 Dec 2025AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 143(1)Section 143(2)Section 234BSection 250Section 801Section 80P(2)(a)Section 80P(4)Section 8o

…upreme Court reported in 431 ITR 1 in the case of Mavilayi Service Co-operative Bank Ltd. v. CIT and in the case of Kerala State Co-operative Agricultural and Rural Development Bank Ltd. KSCARDB v. the Assessing Officer, Trivandrum and Ors. reported in (2023) 458 ITR 384 wherein the Hon’ble Supreme Court has held that the co-operative banks are necessarily a species of the co-operative society. Therefore the interest income earned from the said investments with the other co-operative societies are eligible for deduction u/s. 80P(2)(d) of the Act. 9. Even though this issue was considered by the Single Member Benc…

INFINITY TOWERS CO OP HSG SOC LTD ,MUMBAI vs. ITO 22(1)(1), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 3557/MUM/2025[2022-23]Status: DisposedITAT Mumbai25 Nov 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Neelam Jadhav a/wFor Respondent: Shri Bhagirath Ramawat, (SR.DR.)

Section 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

…tion claimed by the appellant u/s 80P(2)(d) taking into consideration the judgement passed by Hon'ble Apex Court in the case of Kerala State Cooperative Agricultural and Rural Development Bank Ltd v. Assessing Officer [2023] 154 taxmann.com 305/295 Taxman 675/458 ITR 384 (SC). The relevant extract is as follows- "28. Having heard learned advocates for the respective parties and considering the controversy arising in these tax appeals, we are of the opinion that the controversy sought to be canvassed with regard to deduction under section 80P(2)(d) of the Act is no more res integra in view of the decision of this…

INFINITY TOWERS CO OPERATIVE HOUSING SOCIETY LIMITED,MUMBAI vs. ITO 22(1)(1), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 3556/MUM/2025[2021-22]Status: DisposedITAT Mumbai25 Nov 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Neelam Jadhav a/wFor Respondent: Shri Bhagirath Ramawat, (SR.DR.)

Section 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

INFINITY TOWERS CO OPERATIVE HOUSING SOCIETY LIMITED ,MUMBAI vs. ITO -22(1)(1), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 3555/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Nov 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Neelam Jadhav a/wFor Respondent: Shri Bhagirath Ramawat, (SR.DR.)

Section 139(1)Section 143(1)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

KAYANNA SERVICE CO-OPERATIVE BANK,KOZHIKODE vs. ITO, KRL-W-(32)(3), KOZHIKODE

In the result, both appeals of the assessee bearing ITA No

ITA 656/COCH/2025[2023-24]Status: DisposedITAT Cochin13 Nov 2025AY 2023-24

Bench: SHRI. INTURI RAMA RAO (Accountant Member), SHRI. ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Anandakumar, AdvFor Respondent: Shri Leena Lal, (SR.AR.)

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

…l reliance was placed on the order of PCIT Vs Annasaheb Patil Mathadi Kamgar Sahakari Pathpedi Limited, Civil Appeal No. 8719/2022 dated 20/04/2023and Kerala State Co-Operative Agricultural and Rural Development Bank Ltd. KSCARDB vs. Assessing Officer, [2023] 458 ITR 384 (SC) where the Hon’ble Apex Court categorically stated that cooperative bank is the cooperative society and not acted as Bank under Banking Regulation Act,1949. We note the orders of the coordinate benches of ITAT who have taken same view in favour of the assessee. Our respectful finding is the order relied by the revenue is factually distinguish…

KAYANNA SERVICE CO-OPERATIVE BANK,KOZHIKODE vs. ITO, KRL-W-(32)(3), KOZHIKODE

In the result, both appeals of the assessee bearing ITA No

ITA 655/COCH/2025[2020-21]Status: DisposedITAT Cochin13 Nov 2025AY 2020-21

Bench: BEFORESHRI. INTURI RAMA RAO, ACCOUNTANT MEMBERAND SHRI. ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Anandakumar, AdvFor Respondent: Shri Leena Lal, (SR.AR.)

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

BHASKARA EMPLOYEES CREDIT CO-OPERATIVE SOCIETY LIMITED ,BENGALURU vs. INCOME TAX OFFICER, WARD-4(2)(2), BANGALORE

ITA 1048/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Sept 2025AY 2017-18

Bench: Shri Prashant Maharishiassessment Year : 2017-18

For Appellant: Shri Siva Prasad Reddy, ITPFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for the Revenue

Section 143(3)Section 80Section 80P

…annot be denied. 7. Before us the assessee distinguished the decision of the Hon’ble Karnataka High Court and further relied upon the decision of the Hon’ble Supreme Court in case of Kerala State Cooperative Agricultural And Rural Development Bank Ltd (2023) 458 ITR 384 (SC) and as well as the decision of the case of Mavilayi Service Cooperative Bank Ltd (2021) 123 taxmann.com 161 (SC). It submits that the issue is squarely covered in favour of the assessee by the Page 4 of 18 decision of the coordinate bench also (ITA No.1724/Bangalore/2019 dated 22/11/2021 for AY 2014 – 15) wherein it is held that interest in…

PANAMARAM SERVICE CO-OPERATIVE BANK LTD,PANAMARAM, WAYANAD vs. JCIT, RANGE-2, KOZHIKODE

In the result, appeal filed by the assessee stands dismissed

ITA 433/COCH/2025[2015-16]Status: DisposedITAT Cochin14 Aug 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: ------- None -------For Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 269SSection 271DSection 271ESection 274Section 80PSection 80P(2)

…he appellant co- Panamaram Service Co-op. Bank Ltd. operative society does not enjoy a banking license issued by the RBI. The Hon’ble Apex Court in the case of Kerala State Co- operative Agricultural & Rural Development Bank Ltd. vs. Assessing Officer (2023) 458 ITR 384 (SC) categorically held that in the absence of license to carry on the banking business by a cooperative society, it cannot be considered as a co-operative bank. It is an admitted fact that the appellant does not enjoy the license issued by the RBI to carry on the business of banking. Therefore, the contention that it is a co-operative bank canno…

PANAMARAM SERVICE CO-OPERATIVE BANK LTD,PANAMARAM vs. JCIT, RANGE-2, KOZHIKODE

In the result, appeal filed by the assessee stands dismissed

ITA 432/COCH/2025[2015-16]Status: DisposedITAT Cochin14 Aug 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

For Appellant: ------- None -------For Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 269SSection 271DSection 271ESection 274Section 80PSection 80P(2)

TMT EMPLOYEES CO OPERATIVE CREDIT SOCIETY LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, THANE

In the result, the appeal filed by the assessee bearing ITA

ITA 3591/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Aug 2025AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankartmt Employees Co-Operative Vs Pcit, Thane-1 B Wing, Ashar It Park, 6Th Floor, Credit Society Ltd, Shop No.10, Prashaskiya Road No.16Z, Wagle Industrial Bhavan, Then M P (Tmt) Estate, Thane (West)-400 604 Employees Ccs, Wagle Estate, Wagle Aagar, Mumbai-400 604 Pan: Aaeat4545J Applicant Respondent

For Appellant: Shri Venugopal Nair, CAFor Respondent: Shri Ritesh Mishra, CIT DR

Section 143(1)Section 143(3)Section 144BSection 263Section 80PSection 80P(2)(d)

…sidering the decision of the Hon’ble Supreme 4 ITA 3591/Mum /2025 TMT Employees Co-operative Credit Society Ltd Court in Kerala State Co-operative Agricultural and Rural Development Bank Ltd. v. Assessing Officer [2023] 154 taxmann.com 305 / 295 Taxman 675 / 458 ITR 384 (SC). The relevant portion of the Gujarat High Court’s decision reads as follows: "28. Having heard learned advocates for the respective parties and considering the controversy arising in these tax appeals, we are of the opinion that the controversy sought to be canvassed with regard to deduction under section 80P(2)(d) of the Act is no more res…

M/S. THE THIRUNELLY SERVICE CO-OPERATIVE BANK,WAYANAD vs. JCIT, RANGE-2, KOZHIKODE

ITA 421/COCH/2025[2015-16]Status: DisposedITAT Cochin04 Aug 2025AY 2015-16

For Appellant: Shri Arun Raj S, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 269SSection 271DSection 274Section 80P

…not be accepted for the reason that the appellant co- operative society does not enjoy a banking license issued by the RBI. The Hon'ble Apex Court in the case of Kerala State Co-operative Agricultural & Rural Development Bank Ltd. vs. Assessing Officer (2023) 458 ITR 384 (SC) categorically held that in the absence of license to carry on the banking business by a cooperative society, it cannot be considered as a co-operative bank. It is an admitted fact that the appellant does not enjoy the license issued by the RBI to carry on the business of banking. Therefore, the contention that it is a co-operative bank canno…

M/S. THE THIRUNELLY CO-OPERATIVE BANKLTD.,WAYANAD vs. JCIT RANGE-2, KOZHIKODE

In the result, appeal filed by the assessee stands dismissed

ITA 420/COCH/2025[2015-16]Status: DisposedITAT Cochin04 Aug 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Arun Raj S, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 269SSection 271DSection 274Section 80P

…not be accepted for the reason that the appellant co- operative society does not enjoy a banking license issued by the RBI. The Hon’ble Apex Court in the case of Kerala State Co-operative Agricultural & Rural Development Bank Ltd. vs. Assessing Officer (2023) 458 ITR 384 (SC) categorically held that in the absence of license to carry on the banking business by a cooperative society, it cannot be considered as a co-operative bank. It is an admitted fact that the appellant does not enjoy the license issued by the RBI to carry on the business of banking. Therefore, the contention that it is a co-operative bank canno…

PRATHAMIK KRUSHI PATTIN SAHAKAR SANGH NIYAMIT CHIMMAD,JAMKHANDI vs. INCOME TAX OFFICER, WARD-1, BAGALKOT

ITA 286/BANG/2025[2018-19]Status: DisposedITAT Bangalore04 Aug 2025AY 2018-19

Bench: Shri Prashant Maharishi

For Appellant: Shri Ashok Mudnur, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for the Revenue

Section 143Section 80Section 80P

…] [2021] 123 taxmann.com 161 (SC)/[2021] 279 Taxman 75 (SC)/[2021] 431 ITR 1 (SC)[12-01-2021] and (ii) Kerala State Co-Operative Agricultural & Rural Development Bank Ltd. vs. Assessing Officer [2023] 154 taxmann.com 305 (SC)/[2023] 295 Taxman 675 (SC)/[2023] 458 ITR 384 (SC)[14-09-2023] which now binds us . 9. Honourable supreme court in Mavilayi Service Co-operative Bank Ltd. vs. Commissioner of Income Tax, Calicut [ supra] has extracted certain definitions as under: - What is the Definition of cooperative Societies under the Income -tax Act, 1961? "2. In this Act, unless the context otherwise requires, (19)…

SHRI MAHAVEER CO-OPERATIVE CREDIT SOCIETY LTD,ALAGUR vs. INCOME TAX OFFICER, ALAGUR

ITA 6/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Jul 2025AY 2016-17

Bench: Shri Prashant Maharishi

Section 143(2)Section 143(3)Section 18Section 40Section 80PSection 80P(2)(a)Section 80P(2)(d)

…t [2021] 123 taxmann.com 161 (SC)/[2021] 279 Taxman 75 (SC)/[2021] 431 ITR 1 (SC)[12-01-2021] and (ii) Kerala State Co-Operative Agricultural & Rural Development Bank Ltd. vs. Assessing Officer [2023] 154 taxmann.com 305 (SC)/[2023] 295 Taxman 675 (SC)/[2023] 458 ITR 384 (SC)[14-09-2023] which now binds us . 14. Honourable supreme court in Mavilayi decision [ supra ] has extracted certain definitions as under :- What is the Definition of cooperative Societies under the Income -tax Act, 1961 "2. In this Act, unless the context otherwise requires, — (19) "co-operative society" means a co-operative society registere…

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