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 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 367,154 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 80P Section 143(3)Section 250 Section 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 70 section 80p(2)section 80p(2)(d)

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

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

ITA 1696/PUN/2025[2020-21]Status: DisposedITAT Pune26 Nov 2025AY 2020-21

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…

Puthiyakavu Service Cooperative Bank Ltd, Kollam vs. ITO, Ward-2, Alappuzha

In the result, all three appeals of the assessee are allowed

ITA 790/COCH/2025[2022-23]Status: DisposedITAT Cochin25 Nov 2025AY 2022-23

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Rajakanan, AdvFor Respondent: Smt. Leena Lal, Snr AR

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

…(d) of the Act as held by the Hon'ble Jurisdictional High Court in the case of Pr. CIT vs. Peroorkada Service Co-op. Bank Ltd. [2022] 442 ITR 141 (Ker). The Hon'ble Jurisdictional High Court in the case of Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC). As regards the interest income earned by the appellant co-operative society on interest income from Gold loan, it is also covered by the same judgment. As regards the interest income earned by the appellant co-operative society on interest income from fixed deposits made with the SBI and treasury also qualifies for deduction u/s. 80P(2)(a)(i)…

Puthiyakavu Service Cooperative Bank Ltd, Kollam vs. ITO, Ward-2, Alappuzha

In the result, all three appeals of the assessee are allowed

ITA 789/COCH/2025[2020-21]Status: DisposedITAT Cochin25 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Rajakanan, AdvFor Respondent: Smt. Leena Lal, Snr AR

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

Puthiyakavu Service Cooperative Bank Ltd, Kollam vs. ITO, Ward-2, Alappuzha

In the result, all three appeals of the assessee are allowed

ITA 788/COCH/2025[2018-19]Status: DisposedITAT Cochin25 Nov 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Rajakanan, AdvFor Respondent: Smt. Leena Lal, Snr AR

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

Sridharpur Co-Operative Bank, Bardhaman vs. ITO, Ward-3(2), Burdwan

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

ITA 672/KOL/2024[2017-18]Status: DisposedITAT Kolkata20 Nov 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 250Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘C’ BENCH, KOLKATA Before SHRI GEORGE MATHAN, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No.: 672/KOL/2024 Assessment Year: 2017-18 Sridharpur Co-Operative Bank ITO, Ward-3(2), Burdwan Vs. (Appellant) (Respondent) PAN: AACAS8623A Appearances: Assessee represented by : M. Goenka and S.Goenka, AR. Department represented by : Praveen Kishore, CIT (DR). Date of concluding the hearing : 08-September-2025 Date of pronouncing the order : 20-November-2025 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of the…

Gmedapadu Pacs, Gmedapadu vs. ITO, Ward-1, Kakinada

ITA 574/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.574/Viz/2025 ("नधा"रण वष"/Assessment Year: 2020-21) G Medapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Sri Kss Sarma, Ca राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 16/10/2025 Hearing: घोषणा क" तार"ख/Date Of 14/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

For Appellant: Sri KSS Sarma, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

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

…आयकर अपील"य अ"धकरण, "वशाखपटनम पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam, “DIVN” Bench, Visakhapatnam Before Shri Manjunatha G., Accountant Member and Shri Ravish Sood, Judicial Member आ.अपी.सं /ITA No.574/Viz/2025 ("नधा"रण वष"/Assessment Year: 2020-21) G MEDAPADU PACS, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. PAN: AAAAG8455A (Appellant) (Respondent) "नधा"रती "वारा/Assessee by: Sri KSS Sarma, CA राज" व "वारा/Revenue by: Dr. Aparna Villuri, Sr. AR सुनवाई क" तार"ख/Date of 16/10/2025 Hearing: घोषणा क" तार"ख/Date of 14/11/2025 Pronouncement: आदेश / ORDER PER. R…

Mumbai Mint Employees Cooperative Credit Society Ltd, Mumbai vs. Income Tax Officer 17 2 4 Mumbai, Mumbai

In the result, the assessee’s appeal is allowed

ITA 5706/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 M/S. Mumbai Mint Income Tax Officer- Employees’ Co-Operative 17(2)(4), Credit Society Ltd., Room No.112, 1St Floor, Vs. I.G. Mint, S.B. Road, Fort, Kautilya Bhavan, Mumbai – 400 001 C-41 To C-43, G Block, Pan: Aaaat8304P Bandra (East), Mumbai - 400061 (Appellant) (Respondent) Present For: Assessee By : Shri Mandar Vaidya, Ld. A.R. Revenue By : Shri Praveen K. Srivastav, Ld. Sr. D.R. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 05.08.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax, (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2017- 18. 2. In This Case, The Assessee Has Claimed Deduction U/S 80P Of The Act To Tune Of Rs.17,05,275/- Being Income Earned From Co- Operative Banks, By Filing Return Of Income On 01.11.2017 Declaring Income As Rs. “Nil”. The Ao Vide Assessment Order Dated 15.12.2019, Disallowed The Said Deduction Claimed By Holding That Benefit On The Amount Of Rs.17,05,275/- U/S 80P(2)(A)(I) Or 80P2(D)

For Appellant: Shri Mandar Vaidya, Ld. A.RFor Respondent: Shri Praveen K. Srivastav, Ld. Sr. D.R

Section 250Section 80PSection 80P(1)Section 80P(2)(a)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…

Maratha Seva Sangh Sanchlit Dhule Dist Nagari Sahakari Patsanstha Ltd, Dhule vs. Assessment Unit, Itd, Delhi

In the result, appeal of the assessee is allowed

ITA 2183/PUN/2025[2015-16]Status: DisposedITAT Pune14 Nov 2025AY 2015-16

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2183/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Maratha Seva Sangh Sanchlit V Assessment Unit, Dhule Dist Nagari Sahakari S Itd. Patsanstha Ltd., Plot No.148, Chudamani, Jay Hind Colony, Deopur Dhule, Dhule – 424002. Pan: Aactm4087D Appellant/ Assessee Respondent / Revenue Assessee By Shri Sharad A Shah Revenue By Shri Pawan Bharti (Virtual Hearing) Date Of Hearing 13/11/2025 Date Of Pronouncement 14/11/2025 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.2015-16 Dated 23.07.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 21.02.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 142(1)Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…Interest Income earned by investing Income derived from Business and Profession by a Co-Operative Society was eligible for deduction u/s.80P(2)(a) of the Act. 8. The Hon’ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd. Vs. CIT [2021] 431 ITR 1(SC) observed as under : Quote.“Further, section 80P(4) is to be read as a proviso, which proviso now specifically excludes co-operative banks which are co- operative -societies engaged in banking business i.e. engaged in lending money to members of the public, which have a licence in this behalf from the RBI.” Unquote. ITA No.2183/PUN/2025 [A] 9.…

Pandit Dindayal Upahyey Nagari Sahakari Patpedhi Ltd, Shahada vs. ITO, Ward 1, Dhule

In the result, appeal of the assessee is allowed

ITA 1409/PUN/2025[2017-18]Status: DisposedITAT Pune14 Nov 2025AY 2017-18

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1409/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Pandit Dindayal Upahyey V The Income Tax Officer, Nagari Sahakari Patpedhi Ltd., S Ward -1, Dhule. Near Bohari Market Dondaicha Road, Shahade – 425409. Maharashtra. Pan: Aaald0407C Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Pawan Bharti –Dr(Virtual Hearing) Date Of Hearing 12/11/2025 Date Of Pronouncement 14/11/2025 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.2017-18 Dated 24.02.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 25.11.2019. The Assessee Has Raised The Following Grounds Of Appeal :

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

…Interest Income earned by investing Income derived from Business and Profession by a Co-Operative Society was eligible for deduction u/s.80P(2)(a) of the Act. 8. The Hon’ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd. Vs. CIT [2021] 431 ITR 1(SC) observed as under : Quote.“Further, section 80P(4) is to be read as a proviso, which proviso now specifically excludes co-operative banks which are co- 6 operative -societies engaged in banking business i.e. engaged in lending ITA No.1409/PUN/2025 [A] money to members of the public, which have a licence in this behalf from the RBI.” Unquote.…

Mahilanidhi Souharda Limited, Mangalore vs. Income Tax Officer, Ward-2(1), Mangalore

In the result, the appeal by the assessee for the assessment year 2017-18 is allowed

ITA 1528/BANG/2025[2020-21]Status: DisposedITAT Bangalore14 Nov 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sandeep Chalapathy, CAFor Respondent: Shri Subramanian, JCIT (DR)

Section 142(1)Section 143(2)Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…nder the Karnataka Souharda Sahkari Act, 1997, for dealing with the Nominal Members. In this regard, gainful reference can be made to the subsequent decision rendered by Hon’ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. v/s CIT, Calicut, [2021] 431 ITR 1 (SC), wherein, the Hon’ble Supreme Court, after considering the definition of the term “members” in Kerala Co- operative Societies Act, 1969 held that unlike the Andhra Pradesh Act, which was considered in the case of Citizen Co-operative Society Ltd (supra), “nominal members” are members as defined under the Kerala Act, and therefore, the loans gi…

Mahilanidhi Souharda Limited, Mangalore vs. Income Tax Officer, Ward-2(1), Mangalore

In the result, the appeal by the assessee for the assessment year 2017-18 is allowed

ITA 1527/BANG/2025[2018-19]Status: DisposedITAT Bangalore14 Nov 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sandeep Chalapathy, CAFor Respondent: Shri Subramanian, JCIT (DR)

Section 142(1)Section 143(2)Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

Mahilanidhi Souharda Limited, Mangalore vs. Income Tax Officer, Ward-2(1), Mangalore

In the result, the appeal by the assessee for the assessment

ITA 1526/BANG/2025[2017-18]Status: DisposedITAT Bangalore14 Nov 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Respondent: Shri Sandeep Chalapathy, CA

Section 142(1)Section 143(2)Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…nder the Karnataka Souharda Sahkari Act, 1997, for dealing with the Nominal Members. In this regard, gainful reference can be made to the subsequent decision rendered by Hon'ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. v/s CIT, Calicut, [2021] 431 ITR 1 (SC), wherein, the Hon'ble Supreme Court, after considering the definition of the term “members” in Kerala Co- operative Societies Act, 1969 held that unlike the Andhra Pradesh Act, which was considered in the case of Citizen Co-operative Society Ltd (supra), “nominal members” are members as defined under the Kerala Act, and therefore, the loans gi…

Incometax Officer, Ward-1(1), Tiptur vs. Sriudayaravi Credit Co-Op, Tiptur

In the result, appeals of the Revenue are dismissed

ITA 2095/BANG/2024[2018-19]Status: DisposedITAT Bangalore14 Nov 2025AY 2018-19

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 2(24)(viia)Section 80PSection 80P(2)(a)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI.LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.2094, 2095/Bang/2024 Assessment Years : 2017-18, 2018-19 ITO, Ward - 1, Tiptur. Vs. M/s. Udayravi Credit Coop, Udayaravi Bhavana, 1st Main 7th Cross, K. R. Extension, Tiptur - 572 201, Karnataka. PAN : AAWFS 0981 J APPELLANT RESPONDENT Assessee by : Smt. Harsha J, Advocate Revenue by : Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore. Date of hearing : 30.10.2025 Date of Pronouncement: 14.11.2025 ORDER Per Laxmi Prasad Sahu, Accountant Member : These two appeal…

Incometax Officer, Ward-1, Tiptur vs. Sri Udayravi Credit Co-Op, Tiptur

ITA 2094/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 Nov 2025AY 2017-18

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 2(24)(viia)Section 80PSection 80P(2)(a)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI.LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.2094, 2095/Bang/2024 Assessment Years : 2017-18, 2018-19 ITO, Vs. M/s. Udayravi Credit Coop, Udayaravi Bhavana, 1st Main Ward – 1, 7th Cross, K. R. Extension, Tiptur. Tiptur – 572 201, Karnataka. PAN : AAWFS 0981 J APPELLANT RESPONDENT Assessee by : Smt. Harsha J, Advocate Revenue by : Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore. Date of hearing : 30.10.2025 Date of Pronouncement : 14.11.2025 O R D E R Per Laxmi Prasad Sahu, Accountant Member : These two…

Madhya Pradesh Vidyut Mandal Karmchari Paraspar Sahakari Sanstha Maryadit, Mandsaur vs. Income Tax Officer, Mandsaur

Appeal is allowed for statistical purpose

ITA 833/IND/2025[2018-19]Status: DisposedITAT Indore11 Nov 2025AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshimadhya Pradesh Vidyut Ito, Mandsaur बनाम/ Mandal Karmchari Vs. Paraspar Sahakari Sanstha Maryadit, Shop No.5 Nahar Sayyad Road, Kityani Mandsaur (Assessee/Appellant) (Revenue/Respondent) Pan:Aaaam6716A Assessee By Shri Ashok Ratnawat, Ar Revenue By Shri Anoop Singh, Cit-Dr Date Of Hearing 10.11.2025 Date Of Pronouncement 11.11.2025

Section 142(1)Section 143(1)Section 143(2)Section 144Section 250Section 270A(2)Section 80PSection 80P(2)(a)

…r Sahakari Sanstha Maryadit ITA No.833/Ind/2025- AY:2018-19 “GROUNDS OF APPEAL WITH CASE LAWS 1. The learned CIT(A) erred in confirming disallowance of deduction u/s 80P(2)(a)(i) amounting to 54,26,486/- Mavilayi Service Co- operative Bank Ltd. v. CIT (2021) 431 ITR 1 (SC) - Citizen Co-op. Society Ltd. v. ACIT (2017) 397 ITR 1 (SC). 2. The assessment framed u/s 144 r.w.s. 144B is bad in law as no reasonable opportunity was granted. Tin Box Company v. CIT (2001) 249 ITR 216 (SC). 3. The CIT(A) erred in dismissing the appeal ex parte for alleged non- compliance without adjudicating merits - CIT v. Premkumar Arjund…

Moreshwar Krupa Co Op Housing Society Limited, Mumbai vs. Income Tax Officer Ward 42(1)(3), Mumbai

ITA 5026/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry

Section 143(1)Section 154Section 250Section 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…

The Thimiri Service Cooperative Bank Ltd, Kasaragod vs. ITO, Ward-2, Kasaragod

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

ITA 773/COCH/2025[2014-15]Status: DisposedITAT Cochin07 Nov 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2014-15 Thimiri Service Co-Op. Bank Ltd. .......... Appellant Nhanumaki, Chervathur, Kasaragod 671313 [Pan: Aabat0462H] Vs. The Income Tax Officer, Ward-2, Kasaragod ......... Respondent Assessee By: Shri Ramanatha Prabhu N., Advocate Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 07.11.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (Nfac) Dated 28.08.2025 For Assessment Year (Ay) 2014-15. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Return Of Income For Ay 2014-15 Was Filed On 24.11.2014 Declaring Nil

For Appellant: Shri Ramanatha Prabhu N., AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

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

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH BEFORE SHRI INTURI RAMA RAO, AM AND SHRI MANU KUMAR GIRI, JM Assessment Year: 2014-15 Thimiri Service Co-op. Bank Ltd. .......... Appellant Nhanumaki, Chervathur, Kasaragod 671313 [PAN: AABAT0462H] vs. The Income Tax Officer, Ward-2, Kasaragod ......... Respondent Assessee by: Shri Ramanatha Prabhu N., Advocate Revenue by: Smt. Leena Lal, Sr. D.R. Date of Hearing: 06.11.2025 Date of Pronouncement: 07.11.2025 O R D E R Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi (NFAC) dat…

Koonammoochi Peoples Service Co Op Bank Limited No 603, Koonamoochi vs. ITO, Ward 2(1), Guruvayur

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

ITA 719/COCH/2025[2020-2021]Status: DisposedITAT Cochin07 Nov 2025AY 2020-2021

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2020-21 Koonammoochi Peopes Service Co-Op. Bank Ltd. .......... Appellant Koonammoochi, Guruvayoor 680504 [Pan: Aacak4845L] Vs. The Income Tax Officer, Wd 2(1), Guruvayoor ......... Respondent Assessee By: Shri Ramdas, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 07.11.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (Nfac) Dated 17.05.2025 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That The Appellant Is Primary Agricultural Society. The Return Of Income For Ay 2020-21 Was Filed On 13.01.2021 Declaring Nil Income. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax Officer, Ward-2(1), Guruvayoor (Hereinafter Called "The Ao") Vide Order

For Appellant: Shri Ramdas, CAFor Respondent: Smt. Leena Lal, Sr. D.R

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

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH BEFORE SHRI INTURI RAMA RAO, AM AND SHRI MANU KUMAR GIRI, JM Assessment Year: 2020-21 Koonammoochi Peopes Service Co-op. Bank Ltd. .......... Appellant Koonammoochi, Guruvayoor 680504 [PAN: AACAK4845L] vs. The Income Tax Officer, WD 2(1), Guruvayoor ......... Respondent Assessee by: Shri Ramdas, CA Revenue by: Smt. Leena Lal, Sr. D.R. Date of Hearing: 06.11.2025 Date of Pronouncement: 07.11.2025 O R D E R Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi (NFAC) dated 17.05.2025…

DCIT, Circle-2(1)(1), Surat vs. The Surat Vankar Sahkari Sangh Limited, Surat

In the result, the appeal of the revenue is dismissed

ITA 77/SRT/2025[2017-18]Status: DisposedITAT Surat31 Oct 2025AY 2017-18

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.77/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Dcit, Vs. The Surat Vankar Sahkari Sangh Circle – 2(1)(1), Limited, Surat Opp – Reshamwala Market, Ring Road, Surat - 395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat3159L (Appellant) (Respondent) Appellant By Shri Ravi Kant Gupta, Cit-Dr Respondent By Shri Hiren Vepari, Ca Date Of Hearing 19/08/2025 Date Of Pronouncement 30/10/2025

Section 143(2)Section 194A(3)(v)Section 250Section 80PSection 80P(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…in provision contained in section 80P(1) and (2) consequently, the exclusion of Cooperative Banks extends to Section 80P(2)(d) as well as held by Hon'ble Supreme Court in the case of Mavilayi Service Co-Operative Bank Ltd Vs Commissioner of Income Tax ((2021) 431 ITR 1 (SC). 6. On the basis of the facts and circumstances of the case and in law, the Id. CIT(A) ought to have upheld the order of the Assessing Officer. 7. It is therefore prayed that the order of ld. CIT(A) may kindly be set aside that of the Assessing Officer be restored.” 3. The facts of the case in brief are that the assessee e-filed its return of…

Hosdurg Service Co-Operative Bank Ltd No C 1068, Kanhangad vs. Income Tax Officer, Kasaragod

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

ITA 665/COCH/2025[2014-15]Status: DisposedITAT Cochin30 Oct 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2014-15 Hosdurg Service Co-Op. Bank Ltd. .......... Appellant Kanhangad, Hosdurg, Kasaragod 671315 [Pan: Aaaah0337C] Vs. The Income Tax Officer, Wd-2, Kasaragod ......... Respondent Assessee By: Shri Suresh Kumar Varma, Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 28.10.2025 Date Of Pronouncement: 30.10.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (Nfac) Dated 02.09.2025 For Assessment Year (Ay) 2014-15. 2. Brief Facts Of The Case Are That The Appellant Is Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. The Return Of Income For Ay 2014-15 Was Filed On 22.11.2014 Disclosing Income Of Rs. 7,800/- After Claiming

For Appellant: Shri Suresh Kumar Varma, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 80P(2)(a)

…TR 490 (Ker). 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action of the AO by holding that the decision of the Hon'ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC) is applicable only in respect of co-operative societies engaged in the business of providing credit facilities to its members. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. The learned counsel for the assessee submits before us that the appellant is a co-operative society classified as a primar…