Pr. CIT v. Totagars

395 ITR 611High Court2017#39 most cited

What is Pr. CIT v. Totagars authority for?

Interest income earned by a cooperative society from surplus deposits or investments held with a cooperative bank is not eligible for deduction under Section 80P(2)(d) of the Act.

1,074

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2017 to 2026.

Also referred to as

Pr. CIT v. Totagars · 395 ITR 611 · Section 80P(2)(d) · cooperative society · interest income · cooperative bank · deduction · deposits · investments · eligibility 80P

Also reported as

297 CTR 158

Sections most often in play

Section 80P(2)(d)Section 80P(2)(a)(i)Section 80P(4)Section 143(3)Section 80PSection 250Section 2(19)Section 56

Issues it is cited on

section 80(2)(d)section 2(19)section 80p(4)section 80p(1)section 80p(2)(a)(iii)section 80p(2)(c)section 80(p)(2)(d)section 80p(2)(d)section 194a(3)(v)section 80p(2)section 80p(2)(a)section 80p(2)(a)(i)

Judgments citing Pr. CIT v. Totagars

Sri Bramaramba Pattina Souharda Shakari Sangha Niyamitha, Maski vs. Income Tax Officer, Ward-1, Raichur

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

ITA 189/BANG/2025[2020-21]Status: DisposedITAT Bangalore05 Jan 2026AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri Siva Prasad Reddy, ITPFor Respondent: Shri Subramanian .S, JCIT-DR
Section 142(1)Section 143(2)Section 71Section 80PSection 80P(2)Section 80P(2)(a)

…for deduction u/s. 80P(2)(a)(i) of the Act. The AO had not accepted the said objections and relying on the Division Bench judgment of the Hon’ble Jurisdictional High Court in the case of PCIT, Hubballi vs. The Totagars Co-operative Society reported in (2017) 395 ITR 611 had denied the deduction claimed u/s. 80P(2)(a) of the Act on the interest income earned from the deposits made Page 4 of 11 with the co-operative banks. The AO had also not accepted that the assessee would be eligible for claiming deduction u/s. 80P(2)(d) of the Act since the investments are made with the co-operative banks and not with the co-…

Sri Vishnu Vilas Souharda Pattina Sahakari Sangha Niyamita, Ballari vs. Income Tax Officer, Ward-1 & Tps, Ballari

ITA 1515/BANG/2025[2020-21]Status: DisposedITAT Bangalore31 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri H. Siva Prasad Reddy, ITPFor Respondent: Shri Subramanian S, JCIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 263Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…y the assessee would be treated as income from other sources. In the impugned order, the Ld.PCIT had relied on the another judgment of the Hon’ble Jurisdictional High Court in the case of PCIT, Hubballi vs. The Totagars Co-operative Society reported in (2017) 395 ITR 611 and held that the interest income earned by the assessee would be treated as income from other sources u/s. 56 of the Act. The Ld.PCIT had given a direction to the AO to pass orders accordingly. 9. As against the said order, the present appeal has been filed by the assessee before this Tribunal. 10. At the time of hearing, the Ld.AR submitted t…

The Karnataka State Regn and Stamps Department Officials Multi-Purpose Co-Op Society Limited, Bengaluru vs. ACIT, Circle-2(1)(1), Bengaluru

ITA 1518/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Sandeep Singh Karhail

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri Subramanian – JCIT DR
Section 57

…s.69,41,759/-. The Assessee was asked that why the deduction claimedby the Assessee should not be deleted in view of the decision of the Hon'ble Karnataka High Court in case of Principal Commissioner of Income Tax v/s. Totgars Co-operative Sale Society (2017) 395 ITR 611 wherein the deduction u/s.80P(2)(d) is denied. The Assessee submitted that Assessee is entitled to deduction. However, the Ld. Assessing Officer denied the deduction to the Assessee applying provisions of section 80P(2)(d) relying on the decision of the Hon'ble Karnataka High Court. The deduction was denied of Rs.69,41,759/-. The Assessee preferr…

Pujya Sharanabasaveshwara Pattina Souharda Sahakari Sangha Ni Maski, Maski vs. Income-Tax Office, Ward-1, Raichur

In the result appeal of the assessee is allowed

ITA 1180/BANG/2025[2020-21]Status: DisposedITAT Bangalore29 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailassessment Year : 2020-21

For Appellant: Shri Anil Kumar, CAFor Respondent: Shri Muthu Shankar, CIT(DR)(ITAT), Bengaluru
Section 133Section 143Section 144BSection 263Section 56Section 80

…n the present case. 12. For the reasons stated above, this Court does not find any merit in the present appeal. Hence, the appeal is dismissed. 16. Further in PCIT, Hubballi vs. Totagars Co-operative Sale Society [2017] 83 taxmann.com 140 (Karnataka)/ [2017] 395 ITR 611 (Karnataka)/ [2017] 297 CTR 158 (Karnataka) [16-06-2017] the Hon’ble High court was also drawn attention to both the above decisions and in Para no 19 it held as under: - "19. In our opinion, it would not make a difference, whether the interest income is earned from investments/deposits made in a Scheduled Bank or in a Co-operative Bank. Therefo…

The Brahmaling Multipurpose Co-Op Society Ltd, Belgaum vs. Income Tax Officer, Ward -3, Belgaum

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

ITA 254/PAN/2025[2017-18]Status: DisposedITAT Panaji22 Dec 2025AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

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

…on under Sec. 80P(2) (d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars cooperative Sale Society (2017) 395 ITR 611 (Karn), had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2) (d). At the same time, we find, that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon'ble High Court of Gujarat in the case…

Jammanahally Prathamika Krishi Pattina Sahakara Sangha, Ballupet vs. Income Tax Officer, Ward-2, Hassan

In the result ITA No. 192/Bangalore/2025 filed by the assessee is allowed

ITA 341/BANG/2025[2017-18]Status: DisposedITAT Bangalore22 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 143(3)Section 80

…s evident that the assessee is having Page 7 of 16 interest income, which has to be considered under the head income from other sources. It has been held by the Karnataka High Court in the case of PCIT Vs. Totgars Co-operative Sale Society (2017) reported in 395 ITR 611 (KAR) in which it is held that interest earned by the assessee from surplus deposits kept with a cooperative bank is not eligible for deduction u/s 80P(2)(d). The Court held that Section 80P(2)(d) allows interest or dividend earned by an assessee out of the investments with any other co-operative society and not co-operative bank to be exempt. 1…

Jammanahally Prathamika Krishi Pattina Sahakara Sangha, Sakleshpur vs. Income Tax Officer, Ward -2, Hassan

In the result ITA No. 192/Bangalore/2025 filed by the assessee is allowed

ITA 192/BANG/2025[2017-18]Status: DisposedITAT Bangalore22 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 143(3)Section 80

…s evident that the assessee is having Page 7 of 16 interest income, which has to be considered under the head income from other sources. It has been held by the Karnataka High Court in the case of PCIT Vs. Totgars Co-operative Sale Society (2017) reported in 395 ITR 611 (KAR) in which it is held that interest earned by the assessee from surplus deposits kept with a cooperative bank is not eligible for deduction u/s 80P(2)(d). The Court held that Section 80P(2)(d) allows interest or dividend earned by an assessee out of the investments with any other co-operative society and not co-operative bank to be exempt. 1…

Dy. Commissioner of Income Tax, Satara Circle, Satara vs. Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi, Man, Satara

In the result, the appeal of the Revenue in ITA No

ITA 1801/PUN/2025[2020-21]Status: DisposedITAT Pune18 Dec 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1800 & 1801/Pun/2025 निर्धारण वर्ष / Assessment Years : 2018-19 & 2020-21 Dy. Cit, Satara Circle, Satara अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi, Vs. At Post-Dahiwadi, Tal.-Man Satara, Satara-415508 Pan: Aaoas0059G प्रत्यर्थी / Respondent Shri R.C. Doshi Shri S. Sadananda Singh 11-11-2025 18-12-2025 आदेश / Order Per Astha Chandra, Jm : These Two Appeals Filed By The Revenue Are Directed Against The Two Separate Orders Both Dated 19.05.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To Assessment Year (“Ay”) 2018-19 & 2020-21. Since The Issue(S) Involved Are Identical, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 133(6)Section 143(3)Section 2(19)Section 80PSection 80P(2)(a)

…ve society. Similar view was also taken by the Hon'ble Gujarat High court in the case of Surat Vankar Sahakari Sangh Ltd. vs. ACIT 421 ITR 134. However, on the same issue, Hon'ble Karnataka High court in the case of PCIT vs. Totagars Co-Operative Sale Society 395 ITR 611 (Karnataka) has taken a contrary view holding that interest income earned from deposit with the cooperative bank does not qualify for deduction under section 80P(2)(d) of the Act. As held by the Hon'ble High Court of Bombay in the case of K. Subramanian v. Siemens India Ltd. [1983] 15 Тахтап 594/[1985] 156 ITR 11 (Bom). where there is a conflict…

Dy. Commissioner of Income Tax, Satara Circle, Satara vs. Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi, Tal. Man Satara

In the result, the appeal of the Revenue in ITA No

ITA 1800/PUN/2025[2018-19]Status: DisposedITAT Pune18 Dec 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1800 & 1801/Pun/2025 निर्धारण वर्ष / Assessment Years : 2018-19 & 2020-21 Dy. Cit, Satara Circle, Satara Vs. Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi, At Post-Dahiwadi, Tal.-Man Satara, Satara-415508 Pan: Aaoas0059G अपीलार्थी / Appellant Assessee By : Shri R.C. Doshi Department By : Shri S. Sadananda Singh Date Of Hearing : 11-11-2025 Date Of Pronouncement : 18-12-2025 प्रत्यर्थी / Respondent आदेश / Order Per Astha Chandra, Jm : These Two Appeals Filed By The Revenue Are Directed Against The Two Separate Orders Both Dated 19.05.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To Assessment Year (“Ay”) 2018-19 & 2020-21. Since The Issue(S) Involved Are Identical, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri R.C. DoshiFor Respondent: Shri S. Sadananda Singh
Section 133(6)Section 143(3)Section 2(19)Section 80PSection 80P(2)(a)

…ve society. Similar view was also taken by the Hon'ble Gujarat High court in the case of Surat Vankar Sahakari Sangh Ltd. vs. ACIT 421 ITR 134. However, on the same issue, Hon'ble Karnataka High court in the case of PCIT vs. Totagars Co-operative Sale Society 395 ITR 611 (Karnataka) has taken a contrary view holding that interest income earned from deposit with the cooperative bank does not qualify for deduction under section 80P(2)(d) of the Act. As held by the Hon'ble High Court of Bombay in the case of K. Subramanian v. Siemens India Ltd. [1983] 15 Тахтап 594/[1985] 156 ITR 11 (Bom). where there is a conflict…

Bella Vista Co Operative Housing Society Limited, Mumbai vs. ITO Ward 3(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6594/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Dec 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Bella Vista Co-Operative Income Tax Officer, Housing Society Limited, Ward-3(1), 7Th Floor, Bella Vista, Vs. Room No. 3, 6Th Floor, 20A Oswal Park, B Wing, Pokharan Road-2, Ashar It Park, Road No.16Z, Thane, Wagle Industrial Estate, Maharashtra–400601. Thane (West), [Pan: Aadab2432M] Maharashtra-400604. (Appellant) (Respondent) For Assessee : Shri Ritesh Shiyal For Revenue : Shri B. Laxmi Kanth, Sr.Dr Date Of Hearing : 16-12-2025 Date Of Pronouncement : 17-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Addl/Jcit(A)-3, Bengaluru, Dated 26-09-2025, Pertaining To Assessment Year (Ay) 2020-21. 2. The Limited Issue For Consideration In The Present Matter Relates To Claim Of Exemption U/S 80P(2)(D) Of The Act By The Assessee Co-Operative Society In Respect Of Interest Income Earned On Deposits Placed With Co-Operative Banks.

For Appellant: Shri Ritesh ShiyalFor Respondent: Shri B. Laxmi Kanth, Sr.DR
Section 143(1)Section 154Section 80Section 80PSection 80P(1)Section 80P(2)(d)

…on under Sec. 80P(2) (d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars cooperative Sale Society (2017) 395 ITR 611 (Karn), had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2) (d). At the same time, we find, that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon'ble High Court of Gujarat in the case…

Shree Jagadguru Mouneshwar Pattin Sahakari Sangh Niyamit Kerur, Bagalkot vs. Income Tax Officer, Ward-1, Bagalkot

In the result the appeal filed by the assessee is allowed

ITA 1623/BANG/2025[2020-21]Status: DisposedITAT Bangalore15 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi

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

…easons stated above, this Court does not find any merit in the present appeal. Hence, the appeal is dismissed. 13. Further in Principal Commissioner of Income-tax, Hubballi vs. Totagars Co- operative Sale Society [2017] 83 taxmann.com 140 (Karnataka)/ [2017] 395 ITR 611 (Karnataka)/ [2017] 297 CTR 158 (Karnataka) [16-06-2017] the honourable High court was also drawn attention to both the above decisions and in Para no 19 it held as under: - "19. In our opinion, it would not make a difference, whether the interest income is earned from investments/deposits made in a Scheduled Bank or in a Co-operative Bank. There…

Vijaya Bank Employees Co-Operative Credit Society, Bangalore vs. The Income Tax Officer, Ward 7(2)(3), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 1524/BANG/2025[2022-23]Status: DisposedITAT Bangalore15 Dec 2025AY 2022-23

Bench: Shri Prashant Maharishiassessment Years 2022-23 Appellant / Assessee Vijaya Bank Employees Cooperative Credit Society, R No 1, 67, Ii Floor, K H Road Shantinagar Bangalore 560027 Karnataka Respondent The Income Tax Officer, Ward 7 (2) (3) Bmtc Building Koramangala Bangalore 560095 Pan Aaaav4696A For Appellant Shri Prasanna N Uralal Advocate For Respondent Shri Ganesh R Ghale, Advocate Date Of Hearing 04-11-2025 Date Of Pronouncement 15-12-2025 O R D E R

Section 139(1)Section 143(2)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…easons stated above, this Court does not find any merit in the present appeal. Hence, the appeal is dismissed. 12. Further in Principal Commissioner of Income-tax, Hubballi vs. Totagars Co- operative Sale Society [2017] 83 taxmann.com 140 (Karnataka)/ [2017] 395 ITR 611 (Karnataka)/ [2017] 297 CTR 158 (Karnataka) [16-06-2017] the honourable High court was also drawn attention to both the above decisions and in Para no 19 it held as under: - "19. In our opinion, it would not make a difference, whether the interest income is earned from investments/deposits made in a Scheduled Bank or in a Co-operative Bank. There…

Sreesharada Credit Co-Operative Society Ltd, Udupi vs. ITO Ward- 1&Tps, Udupi

In the result both the appeals filed by the assessee are allowed

ITA 1316/BANG/2025[2020-21]Status: DisposedITAT Bangalore15 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi

Section 80

…easons stated above, this Court does not find any merit in the present appeal. Hence, the appeal is dismissed. 22. Further in Principal Commissioner of Income-tax, Hubballi vs. Totagars Co- operative Sale Society [2017] 83 taxmann.com 140 (Karnataka)/ [2017] 395 ITR 611 (Karnataka)/ [2017] 297 CTR 158 (Karnataka) [16-06-2017] the honourable High court was also drawn attention to both the above decisions and in Para no 19 it held as under: - "19. In our opinion, it would not make a difference, whether the interest income is earned from investments/deposits made in a Scheduled Bank or in a Co-operative Bank. There…

Sreesharada Credit Co-Operative Society Ltd, Udupi vs. ITO Ward- 1&Tps, Udupi

In the result both the appeals filed by the assessee are allowed

ITA 1315/BANG/2025[2018-19]Status: DisposedITAT Bangalore15 Dec 2025AY 2018-19

Bench: Shri Prashant Maharishi

Section 80

…easons stated above, this Court does not find any merit in the present appeal. Hence, the appeal is dismissed. 22. Further in Principal Commissioner of Income-tax, Hubballi vs. Totagars Co- operative Sale Society [2017] 83 taxmann.com 140 (Karnataka)/ [2017] 395 ITR 611 (Karnataka)/ [2017] 297 CTR 158 (Karnataka) [16-06-2017] the honourable High court was also drawn attention to both the above decisions and in Para no 19 it held as under: - "19. In our opinion, it would not make a difference, whether the interest income is earned from investments/deposits made in a Scheduled Bank or in a Co-operative Bank. There…

Clover Everest World Co-Operative Housing Society Limited, Thane vs. ITO, Ward 1(1), Thane

In the result, the appeal of the assessee is allowed

ITA 6376/MUM/2025[2021-22]Status: DisposedITAT Mumbai12 Dec 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2021-22 Clover Everest World Ito, Ward-1(1), Co-Operative Housing Society 6Th Floor, Limited, Vs. Income Tax Department, Clover Everest Complex, Ashar It Park, Clover Everest World Chs, Wagale Estate, Dhokali, Thane, Thane Maharashtra–400607. Maharashtra-400604. [Pan: Aabac8915E] (Appellant) (Respondent) For Assessee : Shri Ruturaj Gurjar For Revenue : Shri Mahesh Shingate, Addl. Cit (Virtually Appeared) Date Of Hearing : 09-12-2025 Date Of Pronouncement : 12-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Addl/Jcit(A)-2, Visakhapatnam, Dated 25-08-2025, Pertaining To Assessment Year (Ay) 2021-22. 2. The Limited Issue For Consideration In The Present Matter Relates To Claim Of Exemption U/S 80P(2)(D) Of The Act By The Assessee Co-Operative Society In Respect Of Interest Income Earned On Deposits Placed With Co-Operative Banks.

For Appellant: Shri Ruturaj GurjarFor Respondent: Shri Mahesh Shingate, Addl. CIT
Section 143(1)Section 154Section 80Section 80PSection 80P(1)Section 80P(2)(d)

…on under Sec. 80P(2) (d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars cooperative Sale Society (2017) 395 ITR 611 (Karn), had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2) (d). At the same time, we find, that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon'ble High Court of Gujarat in the case…

Shree Laxmi Jyot Industrial Co-Op Soc. Ltd, Mumbai vs. ACIT Cir-25(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6371/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Dec 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Shree Laxmi Jyot Industrial Acit, Circle-25(1), Premises Co-Op. Society Pratyaksha Kar Bhawan, Limited, Vs. Bandra Kurla Complex (Bkc), 29-J, Laxmi Industrial Estate, Bandra (East), New Link Road, Mumbai-400051. Andheri West, Mumbai – 400053. [Pan: Aadas7200A] (Appellant) (Respondent) For Assessee : Shri Gajendra Golchha For Revenue : Shri Vikas Chandra, Sr.Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 12-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Addl/Jcit(A)-Mysore, Dated 12-08-2025, Pertaining To Assessment Year (Ay) 2018-19. 2. The Limited Issue For Consideration In The Present Matter Relates To Claim Of Exemption U/S 80P(2)(D) Of The Act By The Assessee Co-Operative Society In Respect Of Interest Income Earned On Deposits Placed With Co-Operative Banks.

For Appellant: Shri Gajendra GolchhaFor Respondent: Shri Vikas Chandra, Sr.DR
Section 80Section 80PSection 80P(1)Section 80P(2)(d)

…on under Sec. 80P(2) (d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars cooperative Sale Society (2017) 395 ITR 611 (Karn), had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2) (d). At the same time, we find, that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon'ble High Court of Gujarat in the case…

Mehsana Taluka Madhyamik Teachars Credit and Consumers Sahakari Mandali, Mehsana vs. ITO, Ward-2, Mehsana Presently Ward-1, Mehsana

In the result, both the appeals of the assessee are allowed

ITA 1923/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21

Bench: Dr.Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Mehal Doshi, A.RFor Respondent: Shri Abhijit, Sr. DR
Section 143(1)(a)Section 263Section 80PSection 80P(2)Section 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR.BRR KUMAR, VICE PRESIDENT & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. Nos.1728 & 1923/Ahd/2025 (Assessment Years: 2015-16 & 2020-21) Mehsana Taluka Madhyamik Vs. Income Tax Officer, Teachers Credit and Consumers Ward-2, Sahakari Mandali, Mehsana. 15 to 18 Krushna Complex, (Present Ward-1, Mehsana) 3rd Floor Radhanpur Cross Roads, Mehasana-384002. [PAN No.AAAJM0991 N] (अपीलाथ" /Appellant ( ""यथ" /Respondent) Appellant by : Shri Mehal Doshi, A.R. Respondent by: Shri Abhijit, Sr. DR Date of Hearing 08.12.2025 Date of Pronouncement 09.12.20…

Mehsana Taluka Madhyamik Teachars Credit and Consumers Sahakari Mandali, Mehsana vs. ITO, Ward-2, Mehsana Presently Ward-1, Mehsana

In the result, both the appeals of the assessee are allowed

ITA 1728/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2015-16

Bench: Dr.Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Mehal Doshi, A.RFor Respondent: Shri Abhijit, Sr. DR
Section 143(1)(a)Section 263Section 80PSection 80P(2)Section 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR.BRR KUMAR, VICE PRESIDENT & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. Nos.1728 & 1923/Ahd/2025 (Assessment Years: 2015-16 & 2020-21) Mehsana Taluka Madhyamik Vs. Income Tax Officer, Teachers Credit and Consumers Ward-2, Sahakari Mandali, Mehsana. 15 to 18 Krushna Complex, (Present Ward-1, Mehsana) 3rd Floor Radhanpur Cross Roads, Mehasana-384002. [PAN No.AAAJM0991 N] (अपीलाथ" /Appellant ( ""यथ" /Respondent) Appellant by : Shri Mehal Doshi, A.R. Respondent by: Shri Abhijit, Sr. DR Date of Hearing 08.12.2025 Date of Pronouncement 09.12.20…

Vyavasaya Seva Sahakari Bank Limited, Halkusagal vs. Income Tax Officer, Ward-1, Gadag

In the result, appeal of the Assessee is allowed

ITA 1475/BANG/2024[2020-21]Status: DisposedITAT Bangalore08 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year: 2020-21 M/S. Vyavasaya Seva Sahakari The Income Tax Officer, Bank Limited, Ward 1, Halkusagal. Vs. Gadag Pan: Aaaav1081D Appellant Respondent

For Appellant: Shri Anil Kumar, CA
Section 143Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…see denied by the Ld. Page 2 of 11 Assessing Officer on the basis of the decision of the Hon’ble Karnataka High Court in case of Principal Commissioner of Income-tax, Hubballi vs. Totagars Co-operative Sale Society [2017] 83 taxmann.com 140 (Karnataka)/[2017] 395 ITR 611 (Karnataka)/[2017] 297 CTR 158 (Karnataka)[16-06-2017]) and thereby making an addition of Rs. 10,20,139/-. The Ld. CIT (A) also confirms the same. 3. The brief facts of the case show that, that the Assessee is a primary credit society engaged in business of providing credit facilities to its members. It filed its return of income on 28.01.2021 a…

Bhavana Co-Op Credit Society Niyamita, Sirsi vs. Income Tax Officer, Ward-1, Sirsi

In the result the appeal filed by the assessee is allowed

ITA 1074/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R
Section 142(1)Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(i)

…ITANo.1074/Bang/2025 M/s. Bhavana Co op Credit Society Niyamitha, Sirsi IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI,VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2020-21 M/s. Bhavana Co-op. Credit Society Niyamita #38, Market Road Principal CIT Vs. Sirsi 581 401 Hubali PAN NO :AACAB5033D APPELLANT RESPONDENT Assessment Year : 2020-21 M/s. Gonikoppal Primary Rural Agricultural Credit Co-operative Society Ltd. Main Road, Gonikoppal Principal CIT Vs. Virajpet Taluk Bengaluru-3 Kodagu 571 213 PAN NO : AAAAG1109M APPELLANT RESPONDENT Appel…