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

442 ITR 141High Court2022#434 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 366,005 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

Sections most often in play

Section 80P(2)(d)Section 80P(2)(a)(i)Section 80PSection 143(3)Section 144BSection 56Section 147Section 80P(4)

Issues it is cited on

section 2(u)section 56(cci)section 56(c)(i)(cci)section 56(c)section 2(d)section 56(i)(ccv)section 5(c)section 5(b)section 22(1)(b)section 2(c)section 22(1)section 80p(1)

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

The Vallapuzha Service Co-Op Bank Ltd, Palakkad vs. The ITO Ward 3, Palakkad

ITA 327/COCH/2023[2012-13]Status: DisposedITAT Cochin26 Mar 2024AY 2012-13

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri V.P. Narayanan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(3)Section 80PSection 80P(1)

…usiness of banking, even as clarified by the Hon'ble Courts time and again, as in Mavilayi SCB Ltd. v. CIT [2021] 431 ITR 1 (SC); Citizen Cooperative Society Ltd. v. Assst. CIT [2017] 397 ITR 1 (SC); Pr. CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker); Mohammed Usman v.…

Royal Indl Estate Co Op Soc Ltd, Mumbai vs. Deputy Commissioner of Income Tax - 20(1), Piramal Chamber, Lalbaug, Parel, Mumbai

In the result, appeal of the assessee is allowed

ITA 3792/MUM/2023[2018-19]Status: DisposedITAT Mumbai29 Feb 2024AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

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

…spiree Premises Co-op. Soc. Ltd., wherein the Tribunal after referring to various decisions has allowed the claim of deduction. Mostly according to the decision of Hon’ble Kerala High Court in the case of PCIT vs. Percoorkada Services Company Bank Ltd. (2022) 442 ITR 141 (Kerala), the claim of deduction of interest income is allowed. 4. In the result, appeal of the assessee is allowed. Order pronounced on 29th February, 2024 /- / (GAGAN GOYAL) JUDICIAL MEMBER Mumbai; Dated: 29/02/2024 Mini Pawar, Sr.P.S Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard fil…

The Mangalorean Garden Homes Co-Operative Housing Society Limited, Mumbai vs. ITO Ward 23 (3)(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 3789/MUM/2023[2016-17]Status: DisposedITAT Mumbai29 Feb 2024AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member)

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

…ing to various decisions has allowed the claim of 2 AY. 2016-17 The Mangalorean Garden Homes Co-op Hsg. Soc. Ltd.. deduction. Mostly according to the decision of Hon’ble Kerala High Court in the case of PCIT vs. Percoorkada Services Company Bank Ltd. (2022) 442 ITR 141 (Kerala), the claim of deduction of interest income is allowed. 4. In the result, appeal of the assessee is allowed. Order pronounced on 29th February, 2024 /- / (GAGAN GOYAL) JUDICIAL MEMBER Mumbai; Dated: 29/02/2024 Mini Pawar, Sr.P.S Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard fi…

M/S Perumbavoor Urban Co-Op Bank Ltd, Aluva vs. The ITO Ward 2, Aluva

In the result, the assessee’s appeal is allowed and the stay application is dismissed as infructuous

ITA 304/COCH/2023[2018-19]Status: DisposedITAT Cochin12 Jan 2024AY 2018-19

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri M. Ramdas, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(3)Section 28Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…from other sources u/s. 56 of the Act. 3. Before us, the assessee’s case was of the same being in any case deductible u/s. 80P(2)(d) of the Act, as held by the Hon'ble jurisdictional High Court in Pr. CIT vs. Peroorkkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker). 4. We have heard the parties, and perused the material on record. The Revenue authorities have, we find, denied the assessee’s claim in view of the decision in Totgar’s Co-operative Sales Society Ltd. vs. ITO [2010] 322 ITR 283 (SC) which, as argued by Shri Ramdas, the learned counsel for the assessee, stands considered in Peroorkkada Ser…

M/S.the Mundakkayam Service Co-Op Bank Ltd, Kottayam vs. The ITO, Kottayam

ITA 73/COCH/2023[2018-19]Status: DisposedITAT Cochin28 Dec 2023AY 2018-19

Bench: Shri Sanjay Arora & Shri Manomohan Dasthe Mundakkayam Service Co- The Income Tax Officer Operative Bank Ltd. Ward – 2 Mundakkayam Vs. Kottayam Kottayam 686513 [Pan:Aaaat8803H] (Appellant) (Respondent)

For Appellant: Shri Prasanth Srinivas, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(3)Section 5Section 59Section 80P(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…assessee made an alternate plea of the impugned disallowance, to the extent not deductible u/s. 80P(2)(a)(i) of the Act, would stand to be deductible u/s. 80P(2)(d), and toward which reliance is placed on the decision in Pr. CIT v. Perroorkada SCB Ltd. [2022] 442 ITR 141 (Ker). 4. We have heard the parties, and perused the material on record. 4.1 The assessee, as is the admitted position, is not a co-operative bank, i.e., within the meaning of the term u/s. 80P(4), which restricts the benefit of deduction u/s. 80P(1) to cooperative societies other than cooperative banks. The next question is if it is in the busi…

Pravara Gramin Bigar Sheti Sahakari Patsanstha Maryadit, Mumbai vs. Principle Commissioner of Income Tax, Thane-1, Mumbai

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

ITA 1970/MUM/2023[2018-2019]Status: DisposedITAT Mumbai16 Oct 2023AY 2018-2019

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 143(3)Section 263Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)

…1 ITA 1970/Mum/2023 Pravara Gramin Bigar Sheti Sahakari Patsanstha Maryadit IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C”, MUMBAI BEFORE SHRI AMIT SHUKLA (JUDICIAL MEMBER) AND Ms. PADMAVATHY S. (ACCOUNTANT MEMBER) I.T.A. No.1970/Mum/2023 (Assessment year : 2018-19) Pravara Gramin Bigar Sheti vs Principal Commissioner of Income- Sahakari Patsanstha Maryadit, A1, tax, Thane-1 Ashar Park, B-Wing, 6th Floor, Road Nirman Ajay Apartment, Dhangar ali Roha, Raigad, Maharashtra, No.16Z, Wagle Industrial Estate, India, Maharashtra-402 109 Thane (W), Maharashtra-400 064 PAN :AAAAP5903A APPELLANT RESPONDENT Presen…

The ITO, WD-2(2), RG-2, Trivandrum vs. M/S.Nagaroor Service Co-Op Bank Ltd, Trivandrum

In the result, the appeals are disposed on the afore-stated terms

ITA 77/COCH/2019[2015-16]Status: DisposedITAT Cochin31 Aug 2023AY 2015-16

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Respondent: Shri Sajith Kumar Das, CI
Section 80P(1)Section 80P(4)

…uries being assessable u/s.56 as income from other sources, the same shall nevertheless be deductible u/s.80P(1) r/ws. 80P(2)(d) qua interest income on deposit with co-operative banks, even as held in Pr.CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker), placing a copy of the same on record. The Hon’ble Court had therein considered the decision by the Hon’ble Apex Court in Totgar’s CSS Ltd. (supra) and Mavilayi Service Co-operative Bank Ltd.(supra).The assessment being u/s.56, would, therefore, be of no consequence. The Revenue was, upon this, provided an opportunity by the Bench to rebut…

The ITO, Trivandrum vs. M/S.Perrorkada Service Co-Op Bank Ltd, Trivandrum

In the result, the appeals are disposed on the afore-stated terms

ITA 48/COCH/2019[2015-16]Status: DisposedITAT Cochin31 Aug 2023AY 2015-16

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Respondent: Shri Sajith Kumar Das, CI
Section 80P(1)Section 80P(4)

…uries being assessable u/s.56 as income from other sources, the same shall nevertheless be deductible u/s.80P(1) r/ws. 80P(2)(d) qua interest income on deposit with co-operative banks, even as held in Pr.CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker), placing a copy of the same on record. The Hon’ble Court had therein considered the decision by the Hon’ble Apex Court in Totgar’s CSS Ltd. (supra) and Mavilayi Service Co-operative Bank Ltd.(supra).The assessment being u/s.56, would, therefore, be of no consequence. The Revenue was, upon this, provided an opportunity by the Bench to rebut…

The ITO, Ward-2(3), Trivandrum vs. M/S.Mundela Serviceco-Op Bank Ltd, Trivandrum

In the result, the appeals are disposed on the afore-stated terms

ITA 143/COCH/2019[2011-12]Status: DisposedITAT Cochin31 Aug 2023AY 2011-12

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Respondent: Shri Sajith Kumar Das, CI
Section 80P(1)Section 80P(4)

…uries being assessable u/s.56 as income from other sources, the same shall nevertheless be deductible u/s.80P(1) r/ws. 80P(2)(d) qua interest income on deposit with co-operative banks, even as held in Pr.CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker), placing a copy of the same on record. The Hon’ble Court had therein considered the decision by the Hon’ble Apex Court in Totgar’s CSS Ltd. (supra) and Mavilayi Service Co-operative Bank Ltd.(supra).The assessment being u/s.56, would, therefore, be of no consequence. The Revenue was, upon this, provided an opportunity by the Bench to rebut…

The ITO, WD-4, Kollam vs. M/S. the Adichanalloor Farmers Service Co-Op Bank Ltd, Kollam

In the result, the appeals are disposed on the afore-stated terms

ITA 134/COCH/2019[2015-16]Status: DisposedITAT Cochin31 Aug 2023AY 2015-16

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Respondent: Shri Sajith Kumar Das, CI
Section 80P(1)Section 80P(4)

…uries being assessable u/s.56 as income from other sources, the same shall nevertheless be deductible u/s.80P(1) r/ws. 80P(2)(d) qua interest income on deposit with co-operative banks, even as held in Pr.CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker), placing a copy of the same on record. The Hon’ble Court had therein considered the decision by the Hon’ble Apex Court in Totgar’s CSS Ltd. (supra) and Mavilayi Service Co-operative Bank Ltd.(supra).The assessment being u/s.56, would, therefore, be of no consequence. The Revenue was, upon this, provided an opportunity by the Bench to rebut…

The ITO, WD-2(5), Trivandrum vs. Pazhayakunnumel Service Co-Op Bank Ltd, Trivandrum

In the result, the appeals are disposed on the afore-stated terms

ITA 121/COCH/2019[2015-16]Status: DisposedITAT Cochin31 Aug 2023AY 2015-16

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Respondent: Shri Sajith Kumar Das, CI
Section 80P(1)Section 80P(4)

…uries being assessable u/s.56 as income from other sources, the same shall nevertheless be deductible u/s.80P(1) r/ws. 80P(2)(d) qua interest income on deposit with co-operative banks, even as held in Pr.CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker), placing a copy of the same on record. The Hon’ble Court had therein considered the decision by the Hon’ble Apex Court in Totgar’s CSS Ltd. (supra) and Mavilayi Service Co-operative Bank Ltd.(supra).The assessment being u/s.56, would, therefore, be of no consequence. The Revenue was, upon this, provided an opportunity by the Bench to rebut…

M/S.Pidavoor Service Co-Op Bank Ltd, Kollam vs. The ITO, WD-4, Kollam

In the result, the appeals are disposed on the afore-stated terms

ITA 414/COCH/2018[2014-15]Status: DisposedITAT Cochin31 Aug 2023AY 2014-15

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Respondent: Shri Sajith Kumar Das, CI
Section 80P(1)Section 80P(4)

…uries being assessable u/s.56 as income from other sources, the same shall nevertheless be deductible u/s.80P(1) r/ws. 80P(2)(d) qua interest income on deposit with co-operative banks, even as held in Pr.CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker), placing a copy of the same on record. The Hon’ble Court had therein considered the decision by the Hon’ble Apex Court in Totgar’s CSS Ltd. (supra) and Mavilayi Service Co-operative Bank Ltd.(supra).The assessment being u/s.56, would, therefore, be of no consequence. The Revenue was, upon this, provided an opportunity by the Bench to rebut…

The ITO, Ward-2(3), Trivandrum vs. M/S.Mundela Serviceco-Op Bank Ltd, Trivandrum

In the result, the appeals are disposed on the afore-stated terms

ITA 151/COCH/2018[2014-15]Status: DisposedITAT Cochin31 Aug 2023AY 2014-15

Bench: Shri Sanjay Arora, Am &Shri Manomohan Das, Jm

For Respondent: Shri Sajith Kumar Das, CI
Section 80P(1)Section 80P(4)

…uries being assessable u/s.56 as income from other sources, the same shall nevertheless be deductible u/s.80P(1) r/ws. 80P(2)(d) qua interest income on deposit with co-operative banks, even as held in Pr.CIT v. Peroorkada Service Co-operative Bank Ltd. [2022] 442 ITR 141 (Ker), placing a copy of the same on record. The Hon’ble Court had therein considered the decision by the Hon’ble Apex Court in Totgar’s CSS Ltd. (supra) and Mavilayi Service Co-operative Bank Ltd.(supra).The assessment being u/s.56, would, therefore, be of no consequence. The Revenue was, upon this, provided an opportunity by the Bench to rebut…

Keezhallur Service Co-Op Bank Ltd, Kannur vs. The ITO Ward 2, Kannur

In the result, the assessee’s appeals are allowed

ITA 164/COCH/2023[2016-17]Status: DisposedITAT Cochin28 Aug 2023AY 2016-17

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

For Appellant: NoneFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR
Section 143(3)Section 80PSection 80P(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…ng deduction u/s. 80P. The same was though allowed in appeal, save to the extent of interest on investment in treasury savings and with other institutions, being covered neither u/s.80P(2)(a)(i) nor u/s. 80P(2)(d), relying on CIT v. Peroorkada SCB Ltd. [2022] 442 ITR 141 (Ker), by the first appellate authority, holding as under:- “8.10 In view of the above, respectfully following the latest decision of the Hon'ble jurisdictional High Court of Kerala in the cases of (1) CIT vs. Peroorkada Service Co-operative Bank; and (2) PCIT vs. Vilappil Service Co- op. Bank Ltd. (2022) 442 ITR 141, order dated 01.11.2021 (supr…

Keezhallur Service Co-Op Bank Ltd, Kannur vs. The ITO Ward 2, Kannur

In the result, the assessee’s appeals are allowed

ITA 163/COCH/2023[2015-16]Status: DisposedITAT Cochin28 Aug 2023AY 2015-16

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

For Appellant: NoneFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR
Section 143(3)Section 80PSection 80P(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…ng deduction u/s. 80P. The same was though allowed in appeal, save to the extent of interest on investment in treasury savings and with other institutions, being covered neither u/s.80P(2)(a)(i) nor u/s. 80P(2)(d), relying on CIT v. Peroorkada SCB Ltd. [2022] 442 ITR 141 (Ker), by the first appellate authority, holding as under:- “8.10 In view of the above, respectfully following the latest decision of the Hon'ble jurisdictional High Court of Kerala in the cases of (1) CIT vs. Peroorkada Service Co-operative Bank; and (2) PCIT vs. Vilappil Service Co- op. Bank Ltd. (2022) 442 ITR 141, order dated 01.11.2021 (supr…

Aryanad Service Co-Op Bank Ltd, Trivandrum vs. ITO Ward -2(3), Trivandrum

In the result, the assessee’s appeal is allowed on the foregoing terms

ITA 922/COCH/2022[2017-18]Status: DisposedITAT Cochin31 Jul 2023AY 2017-18

Bench: Shri Sanjay Arora, Am &Shriabyt.Varkey, Jm

For Appellant: Sri.Arun Raj S, AdvocateFor Respondent: Smt.J.M.Jamuna Devi, Sr. DR
Section 143(3)Section 28Section 36(1)(viii)Section 56Section 80PSection 80P(2)(d)Section 80P(4)

…it is exempt u/s.80P(2)(d), providing deduction in respect of interest or dividend income derived by a co-operative society on its investment with another co-operative society. The Hon'ble jurisdictional High Court has in Pr.CIT v. Peroorkada SCB Ltd. [2022] 442 ITR 141 (Ker), placing a copy of the same on record, clarified that the investment in a co-operative bank would be exigible for deduction u/s.80P(2)(d) inasmuch as the co-operative bank is also a co-operative society, albeit in the business of banking. Smt.Jamuna Devi, the ld.Sr.DR, would, in response, rely on the orders by the Revenue authorities. 4. W…

Rustomjee Aspiree Premises Co-Op Soc. Ltd, Mumbai vs. ITO, Ward 26(2)(5), Mumbai

In the result the appeal filed by the assessee is allowed

ITA 1195/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Jul 2023AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Rustomjee Aspiree Premises Co- Ito Ward 26(2)(5), Op. Soc. Ltd., Room No. 319, 3Rd Floor, Kautilya Vs. Ground Floor, Rustomjee Bhavan, C-41 To C-43, ‘G’ Block Aspiree, Cts No. 628, Ai, Pt Bandra Kurla Complex, Bandra Kurla, Eatern Express Highway, (East), Mumbai-400051. Sion, Mumbai-400022. Pan No. Aabar 4001 L Appellant Respondent

For Appellant: Mr. Dharan GandhiFor Respondent: Ms. Indira Adakil, DR
Section 143(3)Section 80P(2)(d)

…ent of and judgment of the Hon’ble Kerala High Court in the case of PCIT v. Hon’ble Kerala High Court in the case of PCIT v. Hon’ble Kerala High Court in the case of PCIT v. Percoorkada Services Company Bank Ltd. Percoorkada Services Company Bank Ltd.. (2022) 442 ITR 141 . (2022) 442 ITR 141 (Kerala) held that co held that co-operative bank being primarily a co imarily a co-operative society, the assessee is eligible for deduction in he assessee is eligible for deduction interest income earned terest income earned from co-operative bank. operative bank. The relevant finding of the Tribunal os The relevant finding…

Premium Tower Cooperative Housing Society Ltd, Mumbai vs. The Commissioner (Appeals)of Income Tax, Mumbai

In the result, appeal of the assessee is allowed

ITA 1583/MUM/2023[2015-2016]Status: HeardITAT Mumbai17 May 2023AY 2015-2016
Section 143(3)Section 2Section 4Section 80Section 80PSection 80P(2)(d)

…ubstantial questions of law canvassed by the learned counsel for the Revenue even arise in the present case. 8. This view has further been reiterated by the judgment of Hon’ble Kerala High Court in the case of PCIT vs. Percoorkada Service Co. Bank Ltd. (2022) 442 ITR 141 (Kerala) dated 01.11.2021, wherein one of the question before the Hon’ble High Court was, whether the interest income earned from deposits with the banks is eligible for deduction u/s 80P(2). The Hon’ble Kerala High Court has also considered the judgment of Hon’ble Supreme Court in the case of Totagars Cooperative Societies Ltd. 322 ITR 323, wher…

DCIT, Jaipur vs. Rajasthan Cooperative Dairy Federation Ltd, Jaipur

In the result the appeal of the revenue in ITA No

ITA 350/JPR/2022[2018-19]Status: DisposedITAT Jaipur27 Apr 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P. C. Parwal (C.A.)For Respondent: Shri Ajay Malik (CIT) fu/kZkfjrh dh vksj ls@
Section 143(2)Section 2(24)(x)Section 36(1)(va)

…ion made in Para 12 to 15 of its order after considering the decision of Hon’ble Karnataka High Court in reported at 392 ITR 74& 395 ITR 611. 9. It is submitted that Hon’ble Kerala High Court in case of PCIT Vs. Peroorkada Service Cooperative Bank Ltd. (2022) 442 ITR 141 has after considering the entire section 80P and the decision of Supreme Court in case of Totgars Co-operative Sale Society Ltd. Vs. ITO in Para 8.3 held as under:- 8.3 Further, clause (d) deals with interest in respect of any income by way of interest or dividends derived by the Co-operative Societies from its investments with any other Co- ope…

DCIT, Jaipur vs. Rajasthan Cooperative Dairy Federation Ltd, Jaipur

In the result the appeal of the revenue in ITA No

ITA 349/JPR/2022[2016-17]Status: DisposedITAT Jaipur27 Apr 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P. C. Parwal (C.A.)For Respondent: Shri Ajay Malik (CIT) fu/kZkfjrh dh vksj ls@
Section 143(2)Section 2(24)(x)Section 36(1)(va)

…ion made in Para 12 to 15 of its order after considering the decision of Hon’ble Karnataka High Court in reported at 392 ITR 74& 395 ITR 611. 9. It is submitted that Hon’ble Kerala High Court in case of PCIT Vs. Peroorkada Service Cooperative Bank Ltd. (2022) 442 ITR 141 has after considering the entire section 80P and the decision of Supreme Court in case of Totgars Co-operative Sale Society Ltd. Vs. ITO in Para 8.3 held as under:- 8.3 Further, clause (d) deals with interest in respect of any income by way of interest or dividends derived by the Co-operative Societies from its investments with any other Co- ope…