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…