Mavilayi Service Co-operative Bank Ltd. v. CIT

431 ITR 1Supreme Court of India2021#42 most cited

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.

999

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2017 to 2026.

Also referred to as

Mavilayi Service Co-operative Bank Ltd. v. CIT · Section 80P(4) · Section 80P(1) · Section 80P(2) · cooperative bank deduction · RBI license · banking business · cooperative society · deduction under Section 80P(2)(d) · exclusion from 80P · 431 ITR 1

Also reported as

123 Taxmann.com 161279 Taxmann 75

Issues it is cited on

Judgments citing Mavilayi Service Co-operative Bank Ltd. v. CIT

Sridharpur Co-Operative Bank, Burdhaman vs. Income Tax Officer, Ward-2(1), Burdwan

In the result, the appeal of the assessee is allowed

ITA 2106/KOL/2024[2020-21]Status: DisposedITAT Kolkata08 Dec 2025AY 2020-21

Bench: Shri Manunatha G & Shri Sonjoy Sarmai.T.A. No.2106/Kol/2024 Assessment Year: 2020-21 Sridharpur Co-Operative Bank …………………................................……….…Appellant Vill & Po. Hat Sridharpur, Memari-I, Dist- Bardhaman, W.B. – 713146. [Pan: Aacas8623A] Vs. Ito, Ward-2(1), Burdwan…..….………………….…..….......……..…...…..…..Respondent Appearances By: Shri M. Goenka & S. Goenka, Ca, Appeared On Behalf Of The Assessee. Shri Sallong Yaden, Addl. Cit-Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi, For The Assessment Year 2020–21, Whereby The Ld. Cit(A) Sustained The Disallowance Made By The Assessing Officer In Respect Of Deduction Claimed By The Assessee Under Section 80P Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Is A Primary Agricultural Cooperative Credit Society Registered Under The West Bengal Cooperative Societies Act. For The Relevant Assessment Year, The Assessee Filed Its Return Of Income Declaring Nil Taxable Income After Claiming Deduction Of ₹1,99,10,459 Under Section 80P Of The Act. The Case Of The Assessee Was Selected For

Section 80PSection 80P(2)(d)Section 80P(4)

…आयकर अपीलीय अिधकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH KOLKATA Before Shri Manunatha G, Accountant Member and Shri Sonjoy Sarma, Judicial Member I.T.A. No.2106/Kol/2024 Assessment Year: 2020-21 Sridharpur Co-operative Bank …………………................................……….…Appellant Vill & PO. Hat Sridharpur, Memari-I, Dist- Bardhaman, W.B. – 713146. [PAN: AACAS8623A] vs. ITO, Ward-2(1), Burdwan…..….………………….…..….......……..…...…..…..Respondent Appearances by: Shri M. Goenka, And S. Goenka, CA, appeared on behalf of the assessee. Shri Sallong Yaden, Addl. CIT-DR, appeared on behalf of th…