What is Mavilayi Service Co-operative Bank Ltd. v. CIT authority for?

Section 80P(4) serves as a proviso to Section 80P(1) and (2), excluding only cooperative banks that are cooperative societies and possess an RBI license for banking business. Its purpose is to exclude cooperative banks operating like commercial banks that lend money to the public.

How many judgments cite Mavilayi Service Co-operative Bank Ltd. v. CIT?

999 judgments on BharatTax cite Mavilayi Service Co-operative Bank Ltd. v. CIT (431 ITR 1), spanning 2017 to 2026.

Which sections of the Income Tax Act does Mavilayi Service Co-operative Bank Ltd. v. CIT 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 80P, Section 143(3), Section 250.

Mavilayi Service Co-operative Bank Ltd. v. CIT (431 ITR 1)

Horizon Co-Operative Housing Society Limted, Mumbai vs. ITO Ward 21(1)(4), Mumbai

ITA 8468/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Feb 2026AY 2013-14

Bench: Shri Amit Shukla () & Shri Girish Agrawal () Ι.Τ.Α. Νο. 8468 & 8469/Mum/2025

Section 143(3)Section 2(19)Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…since the matter was pending before the Tribunal, the claim could not be allowed. In appeal, the Ld. CIT(A) affirmed the disallowance by placing reliance upon the judgment of the Hon'ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. vs. CIT (2021) 431 ITR 1 and the decision of the Hon'ble Karnataka High Court in DCIT vs. Totgars Co-operative Sale Society Ltd. (2017) 83 taxmann.com 140, and concurred with the view that interest earned from co- operative banks would not qualify for deduction under section 80P(2)(d). 6. Before us, it has been submitted that the issue now stands squarely covered in favour…

Bardc Bank, Bhatkal vs. National E-Assessment Centre, Delhi

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

ITA 297/PAN/2024[2018-19]Status: DisposedITAT Panaji17 Feb 2026AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.296 & 297/Pan/2024 (A.Y. 2017-18 & 2018-19) Bardc Bank Bhatkal, Ito-Ward-1, Vs Pld Bank, Main Road, Santerikrupa, . Uttara Kannada, Kaigaroad, Bhatkal S.O. Habbuwada, Karnataka-581320. Karwar-581306, Karnataka. Pan .No. Aaaap1731G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

…embers and therefore the claim u/sec 80P (2) (a) (i) under the Income tax act 1961 is not allowed. The Ld.AR relied on the decision of the Hon’ble Supreme Court in the case of Maviyali Service Co-operative Bank Ltd v CIT reported in 123 taxmann.com 161 (SC) / 431 ITR 1 (SC) has held that ,” when nominal members are defined in the governing law dealings with them are entitled for deduction u/s 80P.”. In the present case the nominal and associate members are recognized by the governing law i.e: The Goa Co-operative Societies Act 2001 and the bye laws of the society. The Ld.DR submitted that "If the society is found…

Bardc Bank, Bhatkal vs. Income Tax Officer, Ward - 1, Karwar

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

ITA 296/PAN/2024[2017-18]Status: DisposedITAT Panaji17 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.296 & 297/Pan/2024 (A.Y. 2017-18 & 2018-19) Bardc Bank Bhatkal, Ito-Ward-1, Vs Pld Bank, Main Road, Santerikrupa, . Uttara Kannada, Kaigaroad, Bhatkal S.O. Habbuwada, Karnataka-581320. Karwar-581306, Karnataka. Pan .No. Aaaap1731G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

…embers and therefore the claim u/sec 80P (2) (a) (i) under the Income tax act 1961 is not allowed. The Ld.AR relied on the decision of the Hon’ble Supreme Court in the case of Maviyali Service Co-operative Bank Ltd v CIT reported in 123 taxmann.com 161 (SC) / 431 ITR 1 (SC) has held that ,” when nominal members are defined in the governing law dealings with them are entitled for deduction u/s 80P.”. In the present case the nominal and associate members are recognized by the governing law i.e: The Goa Co-operative Societies Act 2001 and the bye laws of the society. The Ld.DR submitted that "If the society is found…

The Triplicane Coop Credit Society Ltd., Chennai vs. ITO, Ward-9(1), Chennai

ITA 2993/CHNY/2025[2021-22]Status: DisposedITAT Chennai17 Feb 2026AY 2021-22

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2992&2993/Chny/2025 िनधा"रण वष" /Assessment Year: 2020-21 & 2021-22

For Appellant: Mr. B. Suresh, C.A ""For Respondent: Ms. R. Anitha, Addl. CIT

Section 139(1)Section 148Section 250Section 80ASection 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…आयकर अपीलीय अिधकरण, ‘सी’ "ायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक सद" एवं सु"ी पदमावती यस, लेखा सद" के सम" BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND MS. PADMAVATHY.S, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.2992&2993/Chny/2025 िनधा"रण वष" /Assessment Year: 2020-21 & 2021-22 The Triplicane Cooperative Credit The Income Tax Officer, Society Ltd., Vs. Ward-9(1), Old No.35, New No.73, Chennai. Bharathi Salai, Triplicane, Chennai – 600 005. PAN: AAABT 2681E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Appellant by : Mr. B. Suresh, C.A ""थ" की ओर से /R…

The Triplicane Coop Credit Society Ltd., Chennai vs. ITO, Ward-9(1), Chennai

ITA 2992/CHNY/2025[2020-21]Status: DisposedITAT Chennai17 Feb 2026AY 2020-21

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2992&2993/Chny/2025 निर्धारण वर्ष/Assessment Year: 2020-21 & 2021-22 The Triplicane Cooperative Credit Society Ltd., Old No.35, New No.73, Bharathi Salai, Triplicane, Chennai - 600 005. Pan: Aaaвт 2681E (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से /Respondent By सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख /Date Of Pronouncement The Income Tax Officer, Vs. Ward-9(1), Chennai. (प्रत्यर्थी/Respondent) Mr. B. Suresh, C.A Ms. R. Anitha, Addl. Cit 12.02.2026 17.02.2026 Per Padmavathy.S, A.M: आदेश / Order These Appeals By The Assessee Are Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi, (In Short "Cit(A)") Passed U/S. 250 Of The Income Tax Act, 1961 (In Short "The Act") Both Dated 13.08.2025 For Assessment Year (Ay) 2020-21 & 2021-22. The Common Issue Contended In Both These Appeals Pertain To The Denial Of Deduction U/S.80P(2)(D) For The Interest Received From Chennai Central Cooperative Bank Ltd.

Section 139(1)Section 148Section 250Section 80ASection 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक सदस्य एवं सुश्री पदमावती यस, लेखा सदस्य के समक्ष BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND MS. PADMAVATHY.S, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.2992&2993/Chny/2025 निर्धारण वर्ष/Assessment Year: 2020-21 & 2021-22 The Triplicane Cooperative Credit Society Ltd., Old No.35, New No.73, Bharathi Salai, Triplicane, Chennai - 600 005. PAN: AAAВТ 2681E (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant by प्रत्यर्थी की ओर से /Respondent by सुनवाई की तारीख /Date of Hearing घोषणा की तारीख…

Shri Hanuman Credit Souharda Sahakari Sangh Ltd, Belagavi vs. Income Tax Officer, Ward - 1, Nippani

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

ITA 235/PAN/2025[2017-18]Status: DisposedITAT Panaji16 Feb 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80P(2)(a)

…embers and therefore the claim u/sec 80P (2) (a) (i) under the Income tax act 1961 is not allowed. The Ld.AR relied on the decision of the Hon’ble Supreme Court in the case of Maviyali Service Co-operative Bank Ltd v CIT reported in 123 taxmann.com 161 (SC) / 431 ITR 1 (SC) has held that ,” when nominal members are defined in the governing law dealings with them are entitled for deduction u/s 80P.”. In the present case the nominal and associate members are recognized by the governing law i.e: The Goa Co-operative Societies Act 2001 and the bye laws of the society. The Ld.DR submitted that "If the society is found…

Shree Sant Savta Gramin Bigar Seti Sahakari Patsanstha Maryadit, Pimpalgaon vs. Assessing Officer, Nashik

In the result, appeal of the Assessee is allowed

ITA 1597/PUN/2025[2016-17]Status: DisposedITAT Pune11 Feb 2026AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1597/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Shree Sant Savta Gramin Bigar V Assessment Unit, Seti Sahakari Patsanstha S Income Tax Maryadit, Department, Delhi. Pimpalgaon, Niphad, Maharashtra – 422209. Pan: Aacas4098M Appellant/ Assessee Respondent /Revenue Assessee By Shri Sanket Joshi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 10/02/2026 Date Of Pronouncement 11/02/2026 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], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2016-17 Dated 27.11.2024 Emanating From The Assessment Order Passed Under Section 144 Of The I.T.Act, Dated 05.03.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 148Section 250Section 271(1)(c)Section 271FSection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…el appearing on behalf of the respective parties, the issue involved in the present appeal is squarely covered against the Revenue in view of the decision of this Court in Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 123 taxmann.com 161/279 Taxman 75/431 ITR 1/[2021] 7 SCC 90. This Court, in the aforesaid decision has specifically observed and held that primary Agricultural Credit Societies cannot be termed as Co operative Banks under the Banking Regulation Act and, therefore, such credit societies shall be entitled to exemption under section 80(P)(2) of the Income-tax Act, 1961. 4. Ms. Aakansha Kaul, le…

Everest Grande Commercial Premises Co-Op. Society Ltd, Mumbai vs. ITO, 24 (1)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 8609/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Feb 2026AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhaileverest Grande Commercial Premises Co- Op. Society Ltd Cts 46/34, Plot 3A Everest Grande Society, Mahakali Caves Road, Andheri Kurla Road, ............... Appellant Andheri (East), Mumbai- 400093 Pan: Aaaae5455A

For Appellant: Shri N. R AgrawalFor Respondent: Shri Pravin Salunkhe, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 3Section 80PSection 80P(2)(d)Section 80P(4)

…ection 80P(2)(d) of the Act on the basis that the Co-operative Bank is covered under the provisions of section 80P(4) of the Act. We find that the Hon’ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 123 taxmann.com 161/279 Taxman 75/431 ITR 1 while analysing the provisions of section 80P(4) of the Act held that section 80P(4) is a proviso to the main provision contained in section 80P(1) and (2) and excludes only Co-operative Banks, which are Co-operative Societies and also possesses a licence from RBI to do banking business. The Hon'ble Supreme Court further held that the limited objec…

Aurangabad Division Life Insurance Employees Co-Op Credit Society Ltd, Auranbad vs. ITO, Ward-1(1), Aurangabad

In the result, appeal of the assessee is allowed

ITA 3175/PUN/2025[2020-21]Status: DisposedITAT Pune10 Feb 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3175/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Aurangabad Divison Life V The Income Tax Officer, Insurance Employees Co-Op S Ward-1(1), Aurangabad. Credit Society Ltd., 11, Jeevan Prakash, Lic Office Building Adalat Road, Kranti Chowk, Aurangabad -431005 Pan: Aaaaa2245A Appellant/ Assessee Respondent /Revenue Assessee By Ca Payal Rathi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 09/02/2026 Date Of Pronouncement 10/02/2026 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], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 24.09.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Income Tax Act, 1961

Section 143(3)Section 144BSection 250Section 56Section 66Section 80PSection 80P(2)(a)

…the judgment and order of the High Court set aside. The appellant will have its costs in this court and in the court below.” Unquote. 3.3 The Hon’ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd.Vs. Commissioner of Income Tax, Calicut 431 ITR 1 (SC) dated 12.01.2021 held as under : “21. An analysis of this judgment would show that the question of law that was reflected in paragraph 5 of the judgment was answered in favour of the assessee. The following propositions may be culled out from the judgment:(I) That section 80P of the IT Act is a benevolent provision, which was enacted by Parlia…

Sewa Sahakari Samiti Latabod, Latabod vs. Income Tax Officer, Risali

In the result, appeal of the assessee is allowed

ITA 5/RPR/2026[2016-17]Status: DisposedITAT Raipur05 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.5/Rpr/2026 "नधा"रण वष" /Assessment Year : 2016-17 Sewa Sahakari Samiti Latabod K-6, Anupam Nagar, Raipur (C.G.) Pan: Aahas1552M

For Appellant: Shri Vinit Kumar Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

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

…f the respective parties, the issue involved in the present appeal is squarely covered against the Revenue in view of the decision of this Court in Mavilayi Service Cooperative Bank Limited and Others Vs. Commissioner of Income Tax, Calicut and Another (2021) 7 SCC 90. This Court, in the aforesaid decision has specifically observed and held that primary Agricultural Credit Societies cannot be termed as Co- operative Banks under the Banking Regulation Act and, therefore, such credit societies shall be entitled to exemption under Section 80(P)(2) of the Income Tax Act, 1961. 4. Ms. Aakansha Kaul, learned counsel ap…

The Madras High Court Coop Society Ltd., Chennai vs. ITO, Ncw-4(2), Coimbatore

The appeal of the assessee is allowed

ITA 3265/CHNY/2025[2020-21]Status: DisposedITAT Chennai04 Feb 2026AY 2020-21

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.3265/Chny/2025 िनधा"रण वष" /Assessment Year: 2020-21

For Appellant: Mr. S. Bhupendran, AdvocateFor Respondent: Ms. R. Kavitha, Addl. CIT

Section 250Section 80PSection 80P(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…आयकर अपीलीय अिधकरण, ‘ए’ "ायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI "ी के, उपा"" जॉज" जॉज", एवं सु"ी पदमावती यस, लेखा सद$ के सम" BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENTAND MS. PADMAVATHY.S, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.3265/Chny/2025 िनधा"रण वष" /Assessment Year: 2020-21 The Madras High Court Cooperative The Income Tax Officer, Society Ltd., Vs. Non Corporate Ward-4(2), 214, Paris Corner, High Court Building Coimbatore. S.O., High Court of Madras, Chennai – 600 104. PAN: AAAAT 9768R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ( की ओर से/ Appellant by : Mr. S. Bhupendra…

Primary Agricultural Credit Co-Operative Society, Kodagu vs. Pr. Commissioner of Income Tax, Bengaluru -3, Bengaluru

In the result appeal filed by the assessee is allowed

ITA 1073/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Feb 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Muthu Shankar, CIT(DR)(ITAT), Bengaluru

Section 142Section 143Section 263Section 80Section 80PSection 80P(2)(a)

…TO,230 Taxman 309 which is also after considering the decision of the Hon’ble Supreme Court in case of Totagars Cooperative Sale Society. Further the assessee also put to the kind attention of the learned PCIT that the decision of the Hon’ble Supreme Court in 431 ITR 1 is also required to be considered. 10. The ld. PCIT rejected the contention of the assessee and held that the assessee is not entitled to deduction of such income as it is not business income attributable to the business of the assessee but is income from other sources and further as the assessee has earned interest from cooperative banks, the ded…

Sree Maruthi Co-Operative Housing Society, Bangalore, Karnataka vs. ITO Ward 7(2)(2), 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)

…Karnataka Co-operative Societies Act and therefore the claim made by the assessee that they are entitled for deduction u/s. 80P(2)(d) of the Act seems to be a valid one. The above said view is supported by the judgment of the Hon’ble Supreme 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- oper…

Hira Manek Co Operative Housing Society Limited, Mumbai vs. ITO Ward 34(2)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2020-

ITA 8500/MUM/2025[2020-21]Status: DisposedITAT Mumbai02 Feb 2026AY 2020-21

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

For Appellant: Shri Rajesh Kumar GandhiFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(1)Section 250Section 80P

…ive Bank is covered under the provisions of section 80P(4) of the Act. We find that the Hon’ble Supreme Court in Mavilayi Service Co-operative Bank ITAs No.8499 & 8500/Mum/2025 (A.Ys. 2021-22 & 2020-21) 7 Ltd. v. CIT [2021] 123 taxmann.com 161/279 Taxman 75/431 ITR 1 while analysing the provisions of section 80P(4) of the Act held that section 80P(4) is a proviso to the main provision contained in section 80P(1) and (2) and excludes only Co-operative Banks, which are Co-operative Societies and also possesses a licence from RBI to do banking business. The Hon'ble Supreme Court further held that the limited objec…

Hira Manek Co Operative Housing Society Limited, Mumbai vs. ITO Ward 34(2)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2020-

ITA 8499/MUM/2025[2021-22]Status: DisposedITAT Mumbai02 Feb 2026AY 2021-22

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

For Appellant: Shri Rajesh Kumar GandhiFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(1)Section 250Section 80P

…ive Bank is covered under the provisions of section 80P(4) of the Act. We find that the Hon’ble Supreme Court in Mavilayi Service Co-operative Bank ITAs No.8499 & 8500/Mum/2025 (A.Ys. 2021-22 & 2020-21) 7 Ltd. v. CIT [2021] 123 taxmann.com 161/279 Taxman 75/431 ITR 1 while analysing the provisions of section 80P(4) of the Act held that section 80P(4) is a proviso to the main provision contained in section 80P(1) and (2) and excludes only Co-operative Banks, which are Co-operative Societies and also possesses a licence from RBI to do banking business. The Hon'ble Supreme Court further held that the limited objec…

Income Tax Officer Ward 1 Satara, Satara vs. Karad Patan Taluka Prathmik Shikshak Sahakari Society Limitedty, Karad

In the result, Revenue’s Appeal is dismissed

ITA 2289/PUN/2025[2020]Status: DisposedITAT Pune23 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2289/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Income Tax Officer, V Karad Patan Taluka Prathmik Ward-1, Satara. S Shikshak Sahakari Society Limited, 190 B Shaniwar Peth, Opp.Shivneri Lodge, Karad, Satara – 415110 Pan: Aaaak0559R Appellant / Assessee Respondent / Revenue Assessee By Shri Satish U Nade Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated

Section 143(3)Section 144BSection 250Section 56Section 57Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…or deduction u/s 80P or not! Implications of section 80P(4) in this case. 10. We will discuss Judicial pronouncements on this issue. 10.1 The Hon’ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd.Vs. Commissioner of Income Tax, Calicut 431 ITR 1 (SC) dated 12.01.2021 held as under : “21. An analysis of this judgment would show that the question of law that was reflected in paragraph 5 of the judgment was answered in favour of the assessee. The following propositions may be culled out from the judgment:(I) That section 80P of the IT Act is a benevolent provision, which was enacted by Parlia…

Bannanje Grahakara Vividhoddesha Saharaka Sangha Ltd vs. The Commissioner of Income Tax (Appeals)

The appeal stands disposed of

ITA/55/2025HC Karnataka22 Jan 2026

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

Section 143Section 260Section 56Section 80P(2)Section 80P(2)(a)

…concerned, the matter was remitted to the Assessing Officer for fresh consideration in the light of the judgment of the Hon’ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. and others v. Commissioner of Income Tax, Calicut and another [(2021) 7 SCC 90]. 5. Sri Mahesh R. Uppin, learned counsel appearing for the assessee, fairly submits that insofar as substantial question of law No.2 is concerned, the issue stands covered by the judgment of the High Court of Kerala in ITA No.142/2019 in the case of Principal Commissioner of Income Tax, Thiruvananthapuram v. Vilappil Service Co-operative…

Income Tax Officer Ward-2, Ahmednagar, Ahamednagar vs. Kanifnath Grmain Bigar Sheti Sahakaripatsanstha Maryadit, Maldad

In the result, Revenue’s Appeal is dismissed

ITA 2271/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…cations of section 80P(4) in this case. 6 ITA Nos.2270 & 2271/PUN/2025 [D] 8. We will discuss Judicial pronouncements on this issue. 8.1 The Hon’ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd.Vs. Commissioner of Income Tax, Calicut 431 ITR 1 (SC) dated 12.01.2021 held as under : “21. An analysis of this judgment would show that the question of law that was reflected in paragraph 5 of thejudgment was answered in favour of the assessee. The following propositions may be culled out from thejudgment:(I) That section 80P of the IT Act is a benevolent provision, which was enacted by Parliame…

Income Tax Officer Ward-2, Ahmednagar vs. Kanifnath Grmain Bigar Sheti Sahakari, Maldad Sangamner

In the result, Revenue’s Appeal is dismissed

ITA 2270/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…cations of section 80P(4) in this case. 6 ITA Nos.2270 & 2271/PUN/2025 [D] 8. We will discuss Judicial pronouncements on this issue. 8.1 The Hon’ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd.Vs. Commissioner of Income Tax, Calicut 431 ITR 1 (SC) dated 12.01.2021 held as under : “21. An analysis of this judgment would show that the question of law that was reflected in paragraph 5 of thejudgment was answered in favour of the assessee. The following propositions may be culled out from thejudgment:(I) That section 80P of the IT Act is a benevolent provision, which was enacted by Parliame…

Uoh Staff Cooperative Credit Society Limited, Hyderabad vs. ITO., Ward-8(1), Hyderabad

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

ITA 469/HYD/2025[2021-2022]Status: DisposedITAT Hyderabad21 Jan 2026AY 2021-2022

Bench: the Ld. CIT(A). Before the Ld. CIT(A), the assessee has reiterated its arguments made before the A.O. and claimed that interest earned from fixed deposit with the nationalized banks is also eligible for claiming deduction under Section 80P(2)(a)(i) or Section 80P(2)(d) of the Act because the interest received is forming part of business of the assessee and therefore the same cannot be disallowed under Section 80P(2)(a)(i) of the Act. The Ld. CIT(A), after considering the submissions of the

For Appellant: Shri K. Saikiran, C.AFor Respondent: Ms. P. Sumitha. Sr. A.R

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

…आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बेंच’, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “SMC” Bench, Hyderabad श्री विजय पाल राि, माननीय उपाध्यक्ष एिं श्री मंजूनाथ जी, माननीय लेखा सदस्य SHRI VIJAY PAL RAO, HON’BLE VICE PRESIDENT AND SHRI MANJUNATHA G, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No.469/Hyd/2025 (निर्धारण वर्ा/ Assessment Year: 2021-22) UOH Staff Cooperative Vs. The Income Tax Officer, Credit Society Limited, Ward – 8(1), Hyderabad. Hyderabad. PAN : AAAAU9670K (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee : Shri K. Saikiran, C.A. Represented by र…

Mavilayi Service Co-operative Bank Ltd. v. CIT

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