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

Sections most often in play

Section 80P(2)(d)Section 80P(4)Section 80P(2)(a)(i)Section 80PSection 143(3)Section 250Section 2(19)Section 56

Issues it is cited on

section 22(1)(b)section 5(b)section 80p(1)section 80p(4)section 2(19)section 80p(2)(c)section 22(1)section 80p(2)(a)section 80p(2)(a)(i)section 70section 80p(2)section 80p(2)(d)

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

The Deputy Commissioner of Income Tax, Circle-1(1), Panaji, Ayakar Bhawan vs. Vpk Urban Cooperative Credit Society, Vpk Bhawan

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 252/PAN/2024[2015-16]Status: DisposedITAT Panaji28 Nov 2025AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

The Adarsh Multipurpose Co-Operative Society, Belagavi vs. Income Tax Officer Ward 1-(2), Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 245/PAN/2024[2016-17]Status: DisposedITAT Panaji28 Nov 2025AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Basav Souharda Credit Sahakari Niyamit Bailhongal, Bailhongala vs. Income Tax Officer National E Assessment Center, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 190/PAN/2024[2020-2021]Status: DisposedITAT Panaji28 Nov 2025AY 2020-2021

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Shri Basaveshwar Urban Co Operative Credit Society Ltd, Belagavi vs. Income Tax Officer National E Assessment, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 180/PAN/2024[2020-2021]Status: DisposedITAT Panaji28 Nov 2025AY 2020-2021

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Shri Basaveshwar Urban Co Operative Credit Society Limited, Belagavi vs. Income Tax Officer National E Assessment Centre, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 179/PAN/2024[2018-2019]Status: DisposedITAT Panaji28 Nov 2025AY 2018-2019

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Kumta Adike Marata Sopuharda Sahakari Sangh Niyamit, Kumta vs. Income Tax Officer, Ward - 2, Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 153/PAN/2024[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Samarth Urban Co-Operative Credit Society Ltd, Belgaum vs. Pr. Commissioner of Income Tax, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 152/PAN/2024[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Samarth Urban Co-Operative Credit Society Ltd, Belgaum vs. Pr Commissioner of Income Tax, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 151/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Shri Shradha Credit Souhard Sahakari Niymit Nipani, Nipani vs. ITO, Ward-2 Belgaum, Belgaum

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 144/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Shivagiri Co-Op Credit Society Ltd, Belagavi vs. Income Tax Officer, Ward - 1(3), Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 138/PAN/2024[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Shree Mahila Credit Souhard Sahakari Sangh Niyamit, Belagavi vs. ITO Ward 1 Belagavi, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 117/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 161/PAN/2023[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 160/PAN/2023[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 159/PAN/2023[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 158/PAN/2023[2014-15]Status: DisposedITAT Panaji28 Nov 2025AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Page 6 of 36 Akshaya Co-Op credit society Limited & others. the bye laws of…

Karad Patan Taluka Madhyamik Shala Sevakanchi Sahakari Pathsanstha, Karad vs. ITO Ward 2 Satara, Satara

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

ITA 1135/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1135/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Karad Patan Taluka Vs. Ito, Ward-2, Satara. Madhyamik Shala Sevekanchi Sahakari Pathsanstha, Gala No.9, 10, Malai Towers, Kolhapur Naka, Karad, Dist. Satara- 415110. Pan : Aabtk7825L Appellant Respondent Assessee By : Shri Satish Nade Revenue By : Shri Deepak Kumar Kedia (Virtual) Date Of Hearing 15.10.2025 : Date Of Pronouncement 28.11.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.02.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2020-21. 2. Facts Of The Case, In Brief, Are That The Assessee Is Primary Credit Co-Operative Society Duly Registered Under The Maharashtra State Cooperative Societies Act, 1960 & Engaged In The Activity

For Appellant: Shri Satish NadeFor Respondent: Shri Deepak Kumar Kedia (Virtual)
Section 142(1)Section 143(3)Section 80P(2)(a)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA No.1135/PUN/2025 िनधा"रण वष" / Assessment Year : 2020-21 Karad Patan Taluka Vs. ITO, Ward-2, Satara. Madhyamik Shala Sevekanchi Sahakari Pathsanstha, Gala No.9, 10, Malai Towers, Kolhapur Naka, Karad, Dist. Satara- 415110. PAN : AABTK7825L Appellant Respondent Assessee by : Shri Satish Nade Revenue by : Shri Deepak Kumar Kedia (Virtual) Date of hearing 15.10.2025 : Date of pronouncement 28.11.2025 : आदेश / ORDER PER VINAY BHAMORE, JM: This appeal filed by t…

Saunshi Urban Co-Op Credit Society Limited, Sanushi vs. Income Tax Officer, Ward-1(1), Hubli

ITA 876/BANG/2025[2018-19]Status: DisposedITAT Bangalore28 Nov 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharysaunshi Urban Co-Op Credit Society Ltd. 01 Saunshi Urban Co-Op Credit Society Ltd. Market Road Saunshi Saunshi 581 117 ………. Appellant [Pan: Aaaas5548Q]

For Appellant: Ms. Harsha JFor Respondent: Sri Subramanian
Section 234BSection 250Section 270A(2)Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ooperative banks is eligible for deduction under Section 80P(2)(d) of the Act. Reliance in this regard was placed in judicial precedents listed in Ground No.5 & 6 above. 7.1. In the case of Mavilayi Services Co-operative Bank Limited Vs. CIT, Calicut: [2021] 431 ITR 1 (SC) [12/01/2021], the Hon’ble Supreme Court has held that for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co- operative society is defined in Section 2(19) of the Act, as being a co-operative society registered either under the Co- operative Societies Act, 1912 or under any other law for the time being i…

Rohit Chambers Premises Coop Society Limited, Mumbai vs. Assessing Officer, Mumbai

In the result, appeal filed by the Assessee stands allowed

ITA 5812/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhryassessment Year: 2018-19 M/S. Rohit Chambers Premises Assessing Officer, Coop Society Limited, Ward 26(1)(1), Janmabhoomi Marg, Kautilya Bhavan, G Block Vs. Horniman Circle, Fort, Mumbai Bkc, Bandra Kurla – 400001. Complex, Bandra (E), Pan – Aaaar44550K. Mumbai 400051. (Appellant) (Respondent) Present For: Assessee By : Shri Satish Mody, Ld. Ca Revenue By : Shri Praveen K. Srivastava, Ld. Sr. D.R. Date Of Hearing : 20.11.2025 Date Of Pronouncement : 28.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 16.03.2021, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2018-19. 2. In This Case, The Assessee By Filing Its Return Of Income On Dated 19.09.2018 Had Declared Gross Total Income Of Rs.26,69,680/- Under The Head Income From The Other Sources & Claimed The Same As Exempt Under Section 80P(2)(D) Of The Act.

For Appellant: Shri Satish Mody, Ld. CAFor Respondent: Shri Praveen K. Srivastava, Ld. Sr. D.R
Section 119Section 139Section 2(19)Section 250Section 80Section 80PSection 80P(1)Section 80P(2)(d)

…ed the deduction under section 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 Cooperative Bank Ltd. vs CIT, Calicut, [2021] 431 ITR 1 (SC) 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 Cooperative 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 o…

Shree Raj Crystal Co Op Housing Society Ltd, Mumbai vs. ITO Waqrd 42(1)(5), Mumbai

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

ITA 5769/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry, Jm Shree Raj Crystal Co-Op. Asst. Director Of Income Housing Society Ltd. Tax, Cpc, Bengaluru Royal Complex, Chandawarkar Vs. Road & Eksar Road Junction, Borivali West, Mumbai 400091. Pan/Gir No. Aaas7159K (Appellant) : (Respondent) Assessee By : Shri Bhavesh Gala/Devang Divech Respondent By : Shri Praveen K. Srivastav, Sr. Dr Date Of Hearing : 19.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per Narender Kumar Choudhry, J M:

For Appellant: Shri Bhavesh Gala/DevangFor Respondent: Shri Praveen K. Srivastav, SR
Section 143(1)Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(d)

…ied the deduction under section 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 Cooperative Bank Ltd. vs CIT, Calicut, [2021] 431 ITR 1 (SC) while analyzing 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 Cooperative 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 o…

Agriculture Colleage Farm Co-Operative Credit Society Ltd, Pune vs. ITO Ward-2(1), Pune

ITA 1698/PUN/2025[2017-18]Status: DisposedITAT Pune26 Nov 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1696 & 1698/Pun/2025 िनधा"रण वष" / Assessment Years : 2020-21 & 2017-18 Agriculture College Farm Co- Vs. Ito, Ward-2(1), Pune. Operative Credit Society Ltd., Agricultural College Pune, Shivajinagar, Pune- 411005. Pan : Aadaa3783A Appellant Respondent Assessee By : Shri C. V. Deshpande Revenue By : Smt. N. C. Shilpa Date Of Hearing 19.11.2025 : Date Of Pronouncement 26.11.2025 : आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 22.05.2025 & 06.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2017-18 & 2020-21 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order.

For Appellant: Shri C. V. DeshpandeFor Respondent: Smt. N. C. Shilpa
Section 142(1)Section 143(3)Section 263Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA Nos.1696 & 1698/PUN/2025 िनधा"रण वष" / Assessment Years : 2020-21 & 2017-18 Agriculture College Farm Co- Vs. ITO, Ward-2(1), Pune. operative Credit Society Ltd., Agricultural College Pune, Shivajinagar, Pune- 411005. PAN : AADAA3783A Appellant Respondent Assessee by : Shri C. V. Deshpande Revenue by : Smt. N. C. Shilpa Date of hearing 19.11.2025 : Date of pronouncement 26.11.2025 : आदेश / ORDER PER VINAY BHAMORE, JM: Both the above captioned appeals filed b…