Mantola Cooperative Thrift Credit Society Ltd. v. CIT

110 DTR 89High Court2014#821 most cited

What is Mantola Cooperative Thrift Credit Society Ltd. v. CIT authority for?

A cooperative society is not entitled to claim deduction under Section 80P of the Income Tax Act on interest income earned from deposits made with banks.

125

judgments rely on this decision, according to BharatTax’s citation analysis of 366,369 Indian tax judgments — from 2018 to 2026.

Also referred to as

Mantola Cooperative Thrift Credit Society · Section 80P deduction · interest income from banks · cooperative society · section 80P(2)(d) · section 80P(2)(a)(i) · bank deposits · Totgar's Cooperative Sale Society Ltd · Delhi High Court

Issues it is cited on

Judgments citing Mantola Cooperative Thrift Credit Society Ltd. v. CIT

Ajayshree Gramin Bigar Sheti Sahakari Patsanstha Maryadit, Pune vs. NFAC, Delhi

In the result, appeal of the assessee is allowed

ITA 1427/PUN/2023[2018-19]Status: DisposedITAT Pune08 Mar 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1427/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Ajayshree Gramin Bigar Sheti The National Faceless Sahakari Patasanstha Maryadit, V Assessment At Post Murum, Tal Baramati, S Centre(Nfac), Delhi. Dist Pune, Pune – 412306. Pan: Aaaaa9964E Appellant/ Assessee Respondent /Revenue Assessee By Shri Manoj R Jain – Ar Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 06/03/2024 Date Of Pronouncement 08/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Dated 30.10.2023 For A.Y.2018-19. The Grounds Of Appeal Raised By The Assessee Are As Under : “1. The Learned Cit (A) Has Erred In Confirming The Addition Of Rs.86,59,612/-Made By The Ao On Account Of Disallowance Of Deduction Claimed By The Appellant U/S 80P(2)(A)(I) Of The Act Without Considering The Detailed Submissions Made By The Appellant & Without Passing Any Speaking Order, On The Ground That Only The Income Earned By Providing Credit Facility To Its Members Be Treated Ajayshree Gramin Bigar Sheti Sahakari Patasanstha Maryadit [A]

Section 143(3)Section 57Section 80PSection 80P(2)(a)

…arnataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 taxmann 309 (Kar.) allowing the deduction u/s. 80P on interest income and the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income, earned from banks under similar circumstances. Both the Hon’ble High Courts have taken into consideration the ratio laid down in the case of Totgar’s Cooperative Sale Society Ltd. 322 ITR 283 (SC). There being no direct judgment from the Hon’ble jurisdictional High Court on the point, the…