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.

How many judgments cite PCIT v. Peroorkada Service Co-op. Bank Ltd.?

208 judgments on BharatTax cite PCIT v. Peroorkada Service Co-op. Bank Ltd. (442 ITR 141), spanning 2019 to 2026.

Which sections of the Income Tax Act does PCIT v. Peroorkada Service Co-op. Bank Ltd. come up under?

It is most often cited in judgments turning on Section 80P(2)(d), Section 80P(2)(a)(i), Section 80P, Section 143(3), Section 144B, Section 56.

PCIT v. Peroorkada Service Co-op. Bank Ltd. (442 ITR 141)

Shri Jivico Karmachari Co-Operative Credit Society Limited, Rajkot, Gujarat vs. Income Tax Officer, Ward 2(1)(1), Rajkot, Gujarat

In the result, appeal filed by the assessee is allowed

ITA 48/RJT/2025[2017-18]Status: DisposedITAT Rajkot21 Jul 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.48/Rjt/2025 ("नधा"रण वष" /Assessment Year: (2017-18) Shri Jivico Karmachari Co- Income Tax Officer, Operative Credit Society Ltd. Ward-2(1)(1), Rajkot, Aayakar Vs. Bhawan, Race Course Ring Road, Jivan Prakash, Mahila College Rajkot-360 001 Chowk, Tagore Marg, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaoas 6270 K (अपीलाथ" /Appellant) (""यथ" /Respondent) "नधा"रती क" ओर से /Assessee By : Shri Krutarth Desai, Ar राज"व क" ओर से /Revenue By :Shri Abhimanyu Singh Yadav, Sr-Dr सुनवाई क" तार"ख/ Date Of Hearing : 03/07/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/07/2025 आदेश / O R D E R Per Dr. A.L. Saini, A.M:

For Appellant: Shri Krutarth Desai, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR

Section 142(1)Section 143(3)Section 250Section 56Section 80P(2)(a)Section 80P(2)(d)

…ars 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…

Thevalakara Farmers Service Co-Operative Bank Limited No.4047, Karunagappally vs. ITO, Ward 2, Alappuzha

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

ITA 133/COCH/2025[2020-21]Status: DisposedITAT Cochin30 Jun 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2020-21 Thevalakara Farmers Service Co-Op. Bank Ltd. .......... Appellant Thevalakkara P.O., Karunagappally 690524 [Pan: Aaabt3597M] Vs. The Income Tax Officer, Ward-2, Alappuzha .......... Respondent Appellant By: ------- None ------- Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 02.06.2025 Date Of Pronouncement: 30.06.2025 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 07.02.2024 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 Primacy Agricultural Co-Operative Society. The Return Of Income For Ay 2020-21 Was Filed Declaring Nil Income After Claiming Exemption U/S. 80P Of The Income Tax Act

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 63Section 64Section 80PSection 80P(2)(d)

…mpugned order held that the interest income earned from co-operative bank is eligible for deduction u/s. 80P(2)(d) of the act following the decision of the Hon'ble Jurisdictional High Court in the case of Pr. CIT vs. Peroorkada Service Co-op. Bank Ltd. [2022] 442 ITR 141 (Ker). However, confirmed the addition in respect of interest income earned from Treasury and the interest income earned on saving bank account. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. At the outset we find that there is a delay of 309 days in filing the present appeal. The appellant had fil…

Asco Bank Limited, Arakulam P.O Thodupuzha vs. Income Tax Officer, Ward 1&Tps, Thodupuzha

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

ITA 923/COCH/2024[2017-18]Status: DisposedITAT Cochin27 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2017-18 Asco Bank Limited .......... Appellant Arakulam P.O.Tohodupuzha, Idukki 685591 [Pan: Aaala0637M] Vs. The Income Tax Officer, Ward -1 & Tps .......... Respondent Thodupuzha Appellant By: Smt. G Mini, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 21.05.2025 Date Of Pronouncement: 27.06.2025

For Appellant: Smt. G Mini, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 63Section 64Section 80PSection 80P(2)(a)

…eduction of interest earned on fixed deposits 9. with co-operative banks, the issue also stands settled in favour of the assessee by the decision of 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: - “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…

The Eroor Service Cooperative Bank Limited No E859, Eroor vs. Income Tax Officer, Corporate Ward 2(1), Kochi

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

ITA 259/COCH/2025[2020-2021]Status: DisposedITAT Cochin24 Jun 2025AY 2020-2021

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2020-21 Eroor Service Co-Op. Bank Ltd. .......... Appellant Eroor P.O., Thripunithura, Ernakulam 682306 [Pan: Aacat5303Q] Vs. Ito, Corporate Ward 2(1), Kochi .......... Respondent Appellant By: Shri Amaljit P.J., Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 26.05.2025 Date Of Pronouncement: 24.06.2025 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 03.02.2025 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 Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Return Of Income For Ay 2020-21 Was Filed On 22.12.2020 Declaring Nil

For Appellant: Shri Amaljit P.J., CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 63Section 64Section 80P

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH BEFORE SHRI INTURI RAMA RAO, AM AND SHRI PRAKASH CHAND YADAV, JM Assessment Year: 2020-21 Eroor Service Co-op. Bank Ltd. .......... Appellant Eroor P.O., Thripunithura, Ernakulam 682306 [PAN: AACAT5303Q] vs. ITO, Corporate Ward 2(1), Kochi .......... Respondent Appellant by: Shri Amaljit P.J., CA Respondent by: Smt. Leena Lal, Sr. D.R. Date of Hearing: 26.05.2025 Date of Pronouncement: 24.06.2025 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 03.02.2…

Cheekkilode Service Co-Op Bank Ltd, Kozhikode vs. ITO, Ward-2(3), Kozhikode

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

ITA 353/COCH/2025[2014-15]Status: DisposedITAT Cochin23 Jun 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2014-15 Cheekkilode Service Co-Op. Bank Ltd. .......... Appellant Cheekkilode, Atholi, Kozhikode 673315 [Pan: Aaaac8251E] Vs. The Income Tax Officer, Ward-2(3), Kozhikode .......... Respondent Appellant By: ------- None ------- Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 26.05.2025 Date Of Pronouncement: 23.06.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), Faridabad [Cit(A)] Dated 30.11.2023 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 Classified As Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Its Members. The Return

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

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

…gibility of interest income received from the District Co-operative bank for exemption u/s. 80P(2)(i)(a) of the Act, the issue 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: - “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…

The Thudanganad Service Co-Operative Bank Ltd, Thudanganad vs. ITO, Ward 1, Thodupuzha

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

ITA 332/COCH/2025[2017-18]Status: DisposedITAT Cochin23 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Thudanganad Service Co-Op. Bank Ltd. .......... Appellant Thudanganad P.O., Muttom 685587 [Pan: Aacat5997N] Vs. The Income Tax Officer, Ward-1, Thodupuzha .......... Respondent Appellant By: Shri Arun Raj S., Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 26.05.2025 Date Of Pronouncement: 23.06.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-1, Nashik [Cit(A)] Dated 20.03.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. The Return Of Income For Ay 2017-18 Was Filed On 29.10.2017 Declaring Nil Income. The Ito, Ward 2, Thodupuzha (Hereinafter Called "The Ao") Issued Notices U/S. 143(2) & 142(1) Of The Income Tax Act, 1961 (The Act). In Response To The Notice U/S. 142(1) Dated 09.10.2019, The Assessee Filed Necessary Documents. On Verification Of The Bye Laws & Other Documents It Is Found That The Appellant Is 2 Thudanganad Service Co-Op. Bank Ltd. Engaged In Banking Activity. Against The Said Return Of Income, The Assessment Was Completed By The Ao Vide Order Dated 19.12.2019 Passed U/S. 143(3) Of The Act At A Total Income Of Rs. 14,40,605/-. While Doing So, The Ao Disallowed The Claim For Deduction Of Rs. 14,40,605/- U/S. 80P(2)(D) Of The Act Being Dividend Income Received From Other Co-Operative Societies.

For Appellant: Shri Arun Raj S., AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

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

…e AO. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. I notice that this issue 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: - “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…

The Kalakkodu Service Co-Operative Bank Ltd No.1194, Kollam vs. ITO, Ward 2, Kollam

In the result, both the appeals filed by the assessee are allowed and both the connected stay applications are dismissed

ITA 22/COCH/2025[2018-19]Status: DisposedITAT Cochin12 Jun 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

For Appellant: Shri Sabu C S, CAFor Respondent: Shri Suresh Sivanandan IRS, CIT DR and Smt

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

…available on record. We notice that the instant 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. 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…

The Kalakkodu Service Co-Operative Bank Ltd No.1194, Kollam vs. ITO, Ward 2, Kollam

In the result, both the appeals filed by the assessee are allowed and both the connected stay applications are dismissed

ITA 21/COCH/2025[2016-17]Status: DisposedITAT Cochin12 Jun 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

For Appellant: Shri Sabu C S, CAFor Respondent: Shri Suresh Sivanandan IRS, CIT DR and Smt

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

…available on record. We notice that the instant 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. 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…

M/S Nellimood Service Co-Operative Bank Ltd, Nellimood vs. ITO, Ward-2(2), Thiruvananthapuram

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

ITA 32/COCH/2024[2014-2015]Status: DisposedITAT Cochin10 Jun 2025AY 2014-2015

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarmaassessment Years: 2014-15 M/S Nellimood Service Co- Ito, Ward-2(2), V. Operative Bank Ltd. Thiruvananthapuram

For Appellant: Shri Santhosh P Abraham, AdvFor Respondent: Smt. Leena Lal, Snr AR

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

…material available on record. We notice that 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. 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…

Fact Cd Employees Co Operative Credit Society Ltd No E 709, Ernakulam vs. Ward 1 and Tps, Aluva, Ernakulam

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

ITA 469/COCH/2024[2017-18]Status: DisposedITAT Cochin22 May 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2017-18 Fact Cd Employees Co-Op. Credit Society Ltd........... Appellant 709, Ambalamedu P.O., Ernakulam 682303 [Pan: Aaaaf0134F] Vs. The Income Tax Officer, Ward-1 & Tps, Aluva .......... Respondent

For Appellant: Shri Amaljith P.J., CAFor Respondent: Smt. Leena Lal, Sr. D.R

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

…ty on deposits made with District co-operative bank qualifies for deduction u/s. 80P(2)(d) or not. The issue is no longer res integra in view of the 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: - “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…

Thrissur District Police Co Operative Society Ltd, Thrissur vs. Income Tax Officer, Thrissur

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

ITA 409/COCH/2024[2016-17]Status: DisposedITAT Cochin19 May 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

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

Section 154Section 250Section 253(5)

…19 iii) Deduction under section 80P(2)(d) is available to co- operativesocieties on income earned as interest on investment made with cooperative bankwhich in turn, is a cooperative society itself. [Pr. CIT v. Peroorkada Service Co-Operative Bank Ltd.(2022) 442 ITR 141] iv) The Interest received out of surplus fund invested in the commercial Banks as well as Interest on I. Tax Refund will be treated as ‘Income from Other Sources’. However the cost of fund and related administrative expenses in respect of earning such interest income should also be allowedas deduction u/s 57 of the I.T.Act, 1961. Needless to sa…

Thrissur District Police Co Operative Society Ltd, Thrissur vs. Income Tax Officer, Thrissur

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

ITA 408/COCH/2024[2014-15]Status: DisposedITAT Cochin19 May 2025AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

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

Section 154Section 250Section 253(5)

…19 iii) Deduction under section 80P(2)(d) is available to co- operativesocieties on income earned as interest on investment made with cooperative bankwhich in turn, is a cooperative society itself. [Pr. CIT v. Peroorkada Service Co-Operative Bank Ltd.(2022) 442 ITR 141] iv) The Interest received out of surplus fund invested in the commercial Banks as well as Interest on I. Tax Refund will be treated as ‘Income from Other Sources’. However the cost of fund and related administrative expenses in respect of earning such interest income should also be allowedas deduction u/s 57 of the I.T.Act, 1961. Needless to sa…

Shree Jamnagar Jilla Sahakari Kharid Vechan Sangh Limited, Jamnagar vs. DCIT-Cir-2(1), Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 223/RJT/2025[2018-2019]Status: DisposedITAT Rajkot16 May 2025AY 2018-2019

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.223/Rjt/2025 "नधा"रण वष"/Assessment Year : 2018-19

For Appellant: Ms. Janvi Shah, ARFor Respondent: Shri Dheeraj Kumr Gupta, Sr-DR

Section 142(1)Section 144Section 250Section 80P(2)(d)

…ars 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 Tirurangadi Service Co-Operative Bank Ltd, Malappuram vs. ITO, Ward 3, Malappuram

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

ITA 1058/COCH/2024[2017-18]Status: DisposedITAT Cochin13 May 2025AY 2017-18

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri M. Ramkumar Menon, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH BEFORE SHRI GEORGE GEORGE K., VP AND SHRI INTURI RAMA RAO, AM ITA No. 1058 /Coch/2024 Assessment Year: 2017-18 Tirurangadi Service Co-op. Bank Ltd. .......... Appellant Chemmad, Tirurangadi Post, Malappuram 676306 [PAN: AABAT5445L] vs. The Income Tax Officer, Ward - 3 .......... Respondent Thariff Basar, Tirur 676101 Appellant by: Shri M. Ramkumar Menon, CA Respondent by: Smt. Leena Lal, Sr. D.R. Date of Hearing: 09.04.2025 Date of Pronouncement: 13.05.2025 O R D E R Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the order of th…

Shri Nidhi Credit Co-Oprative Society Limited, Rajkot vs. ITO 3(1)(1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 936/RJT/2024[2014-2015]Status: DisposedITAT Rajkot30 Apr 2025AY 2014-2015

Bench: Dr. Arjun Lal Saini, Am. & Shr Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.936/Rjt/2024 "नधा"रण वष" / Assessment Year: (2014-15)

For Appellant: Shri J.R. Mankodi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

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

…ars 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 Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward-4, Kollam

In the result, appeals filed by the assessee are allowed

ITA 805/COCH/2024[2018-19]Status: DisposedITAT Cochin29 Apr 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

For Appellant: Shri G.Surendranath Rao, A.RFor Respondent: Smt. Leena Lal, Sr. D.R

Section 250Section 80PSection 8O

…im u/s 80P of the Act? 7. We have heard the rival submissions and perused the materials available on record. We are of the considered opinion that the issue in dispute is squarely covered in the case Pr. CIT v. Peroorkada Service Co-Operative Bank Ltd.(2022) 442 ITR 141 held by Hon’ble Kerala High Court wherein it was held as under: 8. We have noted the rival submissions of the counsel appearing for the parties. In the circumstances of this case, the question that falls for consideration is whether, in the facts and circumstances of this case, the interest income earned by the assessee from the deposits made wi…

The Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward 4, Kollam

In the result, appeals filed by the assessee are allowed

ITA 803/COCH/2024[2017-18]Status: DisposedITAT Cochin29 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

For Appellant: Shri G.Surendranath Rao, A.RFor Respondent: Smt. Leena Lal, Sr. D.R

Section 250Section 80PSection 8O

…im u/s 80P of the Act? 7. We have heard the rival submissions and perused the materials available on record. We are of the considered opinion that the issue in dispute is squarely covered in the case Pr. CIT v. Peroorkada Service Co-Operative Bank Ltd.(2022) 442 ITR 141 held by Hon’ble Kerala High Court wherein it was held as under: 8. We have noted the rival submissions of the counsel appearing for the parties. In the circumstances of this case, the question that falls for consideration is whether, in the facts and circumstances of this case, the interest income earned by the assessee from the deposits made wi…

The Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward 4, Kollam

In the result, appeals filed by the assessee are allowed

ITA 802/COCH/2024[2012-13]Status: DisposedITAT Cochin29 Apr 2025AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

For Appellant: Shri G.Surendranath Rao, A.RFor Respondent: Smt. Leena Lal, Sr. D.R

Section 250Section 80PSection 8O

…im u/s 80P of the Act? 7. We have heard the rival submissions and perused the materials available on record. We are of the considered opinion that the issue in dispute is squarely covered in the case Pr. CIT v. Peroorkada Service Co-Operative Bank Ltd.(2022) 442 ITR 141 held by Hon’ble Kerala High Court wherein it was held as under: 8. We have noted the rival submissions of the counsel appearing for the parties. In the circumstances of this case, the question that falls for consideration is whether, in the facts and circumstances of this case, the interest income earned by the assessee from the deposits made wi…

Yudhishtir Cooperative Housing Society Ltd, Mumbai vs. ITO Ward 42(1)(4), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 1784/MUM/2025[2017-18]Status: DisposedITAT Mumbai25 Apr 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeyudhishtir Co-Operative Vs Jao, Ward Mum-W-42(1)(4), Housing Society Ltd, Kautilya Bhavan, Bandra East, Anand Nagar, N.L. Complex, Mumbai-400 051 Dahisar (East), Mumbai-400 068 Pan: Aaaay4170G Appellant Respondent

For Appellant: ShriVidyadhar KhandekarFor Respondent: Shri Asif Kamali (SR. DR.)

Section 139(1)Section 143Section 143(3)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J(SMC)”, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER Yudhishtir Co-operative vs JAO, Ward MUM-W-42(1)(4), Housing Society Ltd, Kautilya Bhavan, Bandra East, Anand Nagar, N.L. Complex, Mumbai-400 051 Dahisar (East), Mumbai-400 068 PAN: AAAAY4170G APPELLANT RESPONDENT Assessee by : ShriVidyadhar Khandekar Respondent by : Shri Asif Kamali (SR. DR.) Date of hearing : 23/04/2025 Date of pronouncement : 25/04/2025 O R D E R Per Anikesh Banerjee (JM): The instant appeal of the assessee was filed against the o…

The Bank Employees Cooperative Credit Society, Kozhikode vs. ITO, Ward 1(3), Kozhikode

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

ITA 169/COCH/2025[2017-18]Status: DisposedITAT Cochin23 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Senior AR

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, COCHIN Before Shri Inturi Rama Rao, Accountant Member ITA No.169/Coch/2025 : Asst.Year 2017-2018 The Bank Employees Co- The Income Tax Officer operative Credit Society v. Ward 1(3) 11/45AKuriyal Lane Kozhikode. Kozhikode – 673 001. PAN : AABAT2177P. (Appellant) (Respondent) Appellant by : --- None --- Respondent by : Smt.Leena Lal, Senior AR Date of Date of Hearing : 13.03.2025 Pronouncement : 23.04.2025 O R D E R This appeal filed by the assessee is directed against the order of the National Faceless Assessment Centre / Commissioner of Income- tax (Appeals) [“C…

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

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

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

Shri Jivico Karmachari Co-Operative Credit Society Limited, Rajkot, Gujarat vs. Income Tax Officer, Ward 2(1)(1), Rajkot, Gujarat

Thevalakara Farmers Service Co-Operative Bank Limited No.4047, Karunagappally vs. ITO, Ward 2, Alappuzha

Asco Bank Limited, Arakulam P.O Thodupuzha vs. Income Tax Officer, Ward 1&Tps, Thodupuzha

The Eroor Service Cooperative Bank Limited No E859, Eroor vs. Income Tax Officer, Corporate Ward 2(1), Kochi

Cheekkilode Service Co-Op Bank Ltd, Kozhikode vs. ITO, Ward-2(3), Kozhikode

The Thudanganad Service Co-Operative Bank Ltd, Thudanganad vs. ITO, Ward 1, Thodupuzha

The Kalakkodu Service Co-Operative Bank Ltd No.1194, Kollam vs. ITO, Ward 2, Kollam

The Kalakkodu Service Co-Operative Bank Ltd No.1194, Kollam vs. ITO, Ward 2, Kollam

M/S Nellimood Service Co-Operative Bank Ltd, Nellimood vs. ITO, Ward-2(2), Thiruvananthapuram

Fact Cd Employees Co Operative Credit Society Ltd No E 709, Ernakulam vs. Ward 1 and Tps, Aluva, Ernakulam

Thrissur District Police Co Operative Society Ltd, Thrissur vs. Income Tax Officer, Thrissur

Thrissur District Police Co Operative Society Ltd, Thrissur vs. Income Tax Officer, Thrissur

Shree Jamnagar Jilla Sahakari Kharid Vechan Sangh Limited, Jamnagar vs. DCIT-Cir-2(1), Jamnagar

The Tirurangadi Service Co-Operative Bank Ltd, Malappuram vs. ITO, Ward 3, Malappuram

Shri Nidhi Credit Co-Oprative Society Limited, Rajkot vs. ITO 3(1)(1), Rajkot

The Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward-4, Kollam

The Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward 4, Kollam

The Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward 4, Kollam

Yudhishtir Cooperative Housing Society Ltd, Mumbai vs. ITO Ward 42(1)(4), Mumbai

The Bank Employees Cooperative Credit Society, Kozhikode vs. ITO, Ward 1(3), Kozhikode