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

Issues it is cited on

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

Lanja Nagari Sahakari Patsanstha Maryadit, Ratnagiri vs. Income Tax Officer, Ratnagiri

Appeal of the assessee is allowed

ITA 1819/PUN/2025[2018-19]Status: DisposedITAT Pune11 Sept 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1819/Pun/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Lanja Nagari Sahakari V The Income Tax Officer, Patsanstha Maryadit, S Ward-1, Ratnagiri. 1923, Satavali Road Lanja, Ratnagiri - 415701. Pan: Aaaal7551N Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S. Shingte – Ar Revenue By Shri Ambarnath Khule - Jcit(Dr) Date Of Hearing 01/09/2025 Date Of Pronouncement | 11/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This 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 A.Y.2018-19 Dated 30.06.2025 Emanating From The Assessment Order Under Section 143(3) R.W.S 143(3A) & 143(3B) Of The Income Tax Act, 1961. The Grounds Of Appeal Raised By The Assessee Are As Under :

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

…आयकर अपीलीय अधिकरण "एस एम सी" न्यायपीठ पुणे में। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES "SMC" :: PUNE BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA No.1819/PUN/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Lanja Nagari Sahakari V The Income Tax Officer, Patsanstha Maryadit, s Ward-1, Ratnagiri. 1923, Satavali Road Lanja, Ratnagiri - 415701. PAN: AAAAL7551N Appellant/ Assessee Respondent / Revenue Assessee by Shri Pramod S. Shingte – AR Revenue by Shri Ambarnath Khule - JCIT(DR) Date of hearing 01/09/2025 Date of pronouncement | 11/09/2025 आदेश/…

Lunkad Sky Vie Co-Operative Housing Society Limited, Pune vs. ITO Ward 7(3), Pune

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

ITA 1463/PUN/2024[2021-22]Status: DisposedITAT Pune26 Aug 2025AY 2021-22

Bench: Shri Dr. Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1463/Pun/2024 िनधा"रण वष" / Assessment Year : 2021-22 Lunkad Sky Vie Co- Vs. Ito, Ward-7(3), Pune. Operative Housing Society Limited, S. No.211, H. No.312, Lunkad Sky Vie, Lohegoan, Vimannagar, Pune- 411014. Pan : Aaaal8573A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 12.08.2025 Date Of Pronouncement : 26.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.05.2024 Passed By Ld. Addl./Jcit(A)-1, Vadodara [‘Ld. Cit(A)’] For The Assessment Year 2021-22. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “(All Grounds Are On An Alternate & Without Prejudice Basis To Each Other)

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Ramnath P. Murkunde
Section 143(1)Section 80P(2)(d)

…various Co-operative banks and other financial institutions. 4. The learned I-T Authorities erred in law and on facts in not appreciating the Supreme Court in the case of The Mavilayi Service Co-Operative Bank Ltd. & ORS. Vs. Commissioner of Income Tax (2021) 431 ITR 1 (SC) has held that interest earned by a Co-operative Society from a Co-operative bank is entitled for deduction u/s. 80P(2)(d) of ITA, 1961. 5. The learned I-T Authorities erred in law and on facts in not appreciating that the interest on deposits with co-operative bank, are covered under the concept of "mutuality" and hence not taxable. 6. Appella…