PCIT v. Peroorkada Service Co-op. Bank Ltd.

442 ITR 141High Court2022#433 most cited

What is PCIT v. Peroorkada Service Co-op. Bank Ltd. authority for?

Interest income earned by a co-operative society from deposits with other co-operative banks, such as district or state co-operative banks, is eligible for deduction under Section 80P(2)(d) of the Income-tax Act, as it is considered income from other sources.

208

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2026.

Also referred to as

Peroorkada Service Co-op. Bank Ltd. · Section 80P(2)(d) · cooperative society deduction · interest income cooperative bank · deposits with cooperative bank · deduction for cooperative societies · Totagars Cooperative Societies Ltd. · Section 80P · eligible for deduction

Issues it is cited on

Judgments citing PCIT v. Peroorkada Service Co-op. Bank Ltd.

SURENDRANAGAR DISTRICT CO OP PRODUCERS UNION LIMITED,SURENDRANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, SURENDRANAGAR CIRCLE

In the result, appeal filed by the assessee is allowed

ITA 429/RJT/2025[2014-15]Status: DisposedITAT Rajkot10 Feb 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 271(1)(c)Section 80P(2)(b)Section 80P(2)(d)

…rs Co- operative Sale Society Ltd(supra) is in the context of Section 80P(2)(a)(i) of the Act and is distinguishable and has been distinguished by lower courts in many judgements which are reproduced below: (a) Peroorkada Service Co-operative Bank Ltd. (2022) 442 ITR 141 (Kerala HC) (b) Totagars Co-operative Sale Society (2017) 392 ITR 74 (Karnataka HC) (c) Vavveru Co-operative Rural Bank Ltd. (2017) 88 taxmann.com 728 (Andhra Pradesh and Telangana HC) (d) State Bank of India vs Commissioner of Income-tax (2016) 389 ITR 578 (Guj. HC); (e) The Uttar Gujarat Uma Co-op. Credit Society Ltd. in ITA Nos. 1670, 1671/A/2…

THE KATTOOR SERVICE COOPERATIVE BANK LIMITED,THRISSUR vs. INCOME TAX OFFICER , WARD 2(1), THRISSUR, THRISSUR

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

ITA 714/COCH/2025[2022-23]Status: DisposedITAT Cochin06 Nov 2025AY 2022-23

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2022-23 Kattoor Service Co-Op. Bank Ltd. .......... Appellant Kattoor P.O., Thrissur 680702 [Pan: Aacat3937A] Vs. The Income Tax Officer, Ward-2(1), Thrissur ......... Respondent Assessee By: Shri Amaljith P.J., Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 03.11.2025 Date Of Pronouncement: 06.11.2025 O R D E R Per Manu Kumar Giri, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [“Cit(A)” In Short] Dated 25.08.2025 For Assessment Year (Ay) 2022-23. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1961. It Is Classified As A Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Return Of 2 Kattoor Service Co-Op. Bank Ltd. Income For Ay 2022-23 Was Filed On 05.11.2022 Disclosing Nil Income After Claiming Deduction U/S. 80P Of The Income Tax Act, 1961 (The Act). Against The Said Return Of Income, The Assessment Was Completed By The Assessment Unit, Income Tax Department (Hereinafter Called "The Ao") Vide Order Dated 19.03.2024 Passes U/S. 143(3) R.W.S. 144B Of The Act At A Total Income Of Rs.5,21,52,939/-. While Doing So, The Ao Denied Deduction U/S.80P(2)(A)(I) & U/S. 80P(2)(D) Of The Act.

For Appellant: Shri Amaljith P.J., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 63Section 64Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ct. 6. The issue related to interest income received from the District Co-operative bank stands adjudicated by Hon'ble Jurisdictional High Court’s decision in the case of PCIT v. Peroorkada Service Co-op. 3 Kattoor Service Co-op. Bank Ltd. Bank Ltd. [2022] 442 ITR 141 (Ker) wherein their Lordships have rejected the Revenue’s identical stand as under: - “12.2 Section 80P deals with Co-operative Societies' computation of income. As already noted, it has four sections and several sub-sections and clauses. The Parliament has considered the various situations in which the exigible income and the deductable income…

PERINGANDOOR SERVICE CO OPERTAIVE BANK LTD,ATHANI, THRISSUR vs. INCOME TAX OFFICER,WARD 2(1), THRISSUR

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

ITA 515/COCH/2025[2022-2023]Status: DisposedITAT Cochin19 Aug 2025AY 2022-2023

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2022-23 Peringandoor Service Co-Op. Bank Ltd. .......... Appellant Athani P.O., Thrissur 680581 [Pan: Aadap3407G] Vs. Income Tax Officer, Wd-2(1), Thrissur .......... Respondent Assessee By: Shri Ramdas M., Ca Revenue By: Ms. Neethu S., Sr. Dr Date Of Hearing: 18.08.2025 Date Of Pronouncement: 19.08.2025 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 Dated 19.05.2025 For Assessment Year (Ay) 2022-23. 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 Classified As A Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Return Of Income For Ay 2022-23 Was Filed On 30.09.2022 Disclosing Nil

For Appellant: Shri Ramdas M., CAFor Respondent: Ms. Neethu S., Sr. DR
Section 143(3)Section 63Section 80PSection 80P(2)(d)

…. The issue related to interest income received from the District Co- operative bank stands adjudicated by Hon'ble Jurisdictional High Court’s 3 Peringandoor Service Co-op. Bank Ltd. decision in the case of PCIT v. Peroorkada Service Co-op. Bank Ltd. [2022] 442 ITR 141 (Ker) wherein their Lordships have rejected the Revenue’s identical stand as under: - “12.2 Section 80P deals with Co-operative Societies' computation of income. As already noted, it has four sections and several sub-sections and clauses. The Parliament has considered the various situations in which the exigible income and the deductable income o…

AMBALLUR SERVICE CO OPERATIVE BANK LIMITED NO 503,MANNAMPETTA, THRISSUR vs. INCOME TAX OFFICER, THRISSUR

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

ITA 79/COCH/2025[2020-2021]Status: DisposedITAT Cochin22 Jul 2025AY 2020-2021

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2020-21 Amballur Service Co-Op. Bank Ltd. .......... Appellant 6/325, Varakkara, Mannampetta, Trissur 680325 [Pan: Aacaa2779B] Vs. The Income Tax Officer, Ward-2(1) Thrissur .......... Respondent Appellant By: Shri M. Ramdas, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 10.06.2025 Date Of Pronouncement: 22.07.2025 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 [Cit(A)] Dated 29.11.2024 For Assessment Year (Ay) 2020-21. 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 Classified As A Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Lending Money To Members For Agricultural & Allied Activities. The Appellant Filed Return Of Income For Ay 2020-21

For Appellant: Shri M. Ramdas, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ld with District Co-operative Bank qualifies for deduction u/s. 80P(2)(d) of the Act. The issue is no longer res integra as it stands adjudicated by Hon'ble Jurisdictional High Court’s decision in the case of PCIT v. Peroorkada Service Co-op. Bank Ltd. [2022] 442 ITR 141 (Ker) wherein their Lordships have rejected the Revenue’s identical stand as under: - 3 Amballur Service Co-op. Bank Ltd. “12.2 Section 80P deals with Co-operative Societies' computation of income. As already noted, it has four sections and several sub-sections and clauses. The Parliament has considered the various situations in which the exigi…

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