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 367,181 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

Datta Digambhar Co Operative Credit Society Ltd, Mumbai vs. CIT(A) NFAC, Delhi

ITA 1819/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Oct 2022AY 2017-18

Bench: Shri Kuldip Singhassessment Year: 2017-18

For Appellant: Shri Kartik Golekar,A.RFor Respondent: Shri Anul Gupta, D.R
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…r Sec. 80P(2)(d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may herein observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative 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…

Income Tax Officer -17(2) (1), Mumbai vs. Mittal Court Premises Co.Op.Society Ltd, Mumbai

In the result, the appeals of the revenue are dismissed

ITA 1537/MUM/2022[2016-17]Status: DisposedITAT Mumbai31 Oct 2022AY 2016-17
For Appellant: Shri Sunil M. LalaFor Respondent: Ms. Mahita Nair (Sr. AR)
Section 194ASection 194A(3)(v)Section 56Section 80PSection 80P(2)(d)Section 80P(4)

…on of this Tribunal. The Ld. DR assailing the action of the Ld. CIT(A)/NFAC relied on the decision of the Hon’ble Karnataka High Court in the case of PCIT Vs. A.Y. 2014-15 to 2016-17 Mittal Court Premises Co-op. Soc. Ltd. Totagar’s Co-operative Sales Society (395 ITR 611 (Kar) which according to her was in revenue’s favour. Per contra, the Ld. AR of the assessee brought to our notice that the Hon’ble Karnataka High Court has passed another order which is in favour of the assessee in PCIT Vs. Totagar’s Co-operative Sales Society (392 ITR 74). Therefore, according to him, when there is no decision of the Hon’ble Ju…

Income Tax Officer -17(2) (1), Mumbai vs. Mittal Court Premises Co.Op.Society Ltd, Mumbai

In the result, the appeals of the revenue are dismissed

ITA 1536/MUM/2022[2014-15]Status: DisposedITAT Mumbai31 Oct 2022AY 2014-15
For Appellant: Shri Sunil M. LalaFor Respondent: Ms. Mahita Nair (Sr. AR)
Section 194ASection 194A(3)(v)Section 56Section 80PSection 80P(2)(d)Section 80P(4)

…on of this Tribunal. The Ld. DR assailing the action of the Ld. CIT(A)/NFAC relied on the decision of the Hon’ble Karnataka High Court in the case of PCIT Vs. A.Y. 2014-15 to 2016-17 Mittal Court Premises Co-op. Soc. Ltd. Totagar’s Co-operative Sales Society (395 ITR 611 (Kar) which according to her was in revenue’s favour. Per contra, the Ld. AR of the assessee brought to our notice that the Hon’ble Karnataka High Court has passed another order which is in favour of the assessee in PCIT Vs. Totagar’s Co-operative Sales Society (392 ITR 74). Therefore, according to him, when there is no decision of the Hon’ble Ju…

Income Tax Officer-17(2) (1), Mumbai vs. Mittal Court Premises Co.Op. Society Ltd, Mumbai

In the result, the appeals of the revenue are dismissed

ITA 1535/MUM/2022[2015-16]Status: DisposedITAT Mumbai31 Oct 2022AY 2015-16
For Appellant: Shri Sunil M. LalaFor Respondent: Ms. Mahita Nair (Sr. AR)
Section 194ASection 194A(3)(v)Section 56Section 80PSection 80P(2)(d)Section 80P(4)

…on of this Tribunal. The Ld. DR assailing the action of the Ld. CIT(A)/NFAC relied on the decision of the Hon’ble Karnataka High Court in the case of PCIT Vs. A.Y. 2014-15 to 2016-17 Mittal Court Premises Co-op. Soc. Ltd. Totagar’s Co-operative Sales Society (395 ITR 611 (Kar) which according to her was in revenue’s favour. Per contra, the Ld. AR of the assessee brought to our notice that the Hon’ble Karnataka High Court has passed another order which is in favour of the assessee in PCIT Vs. Totagar’s Co-operative Sales Society (392 ITR 74). Therefore, according to him, when there is no decision of the Hon’ble Ju…

Sumer Nagar Co-Operative Housing Society Ltd Bldg.No. 1, Mumbai vs. Income Tax Officer WD 32(1) (1), Mumbai

The appeal of the assessee is allowed

ITA 1239/MUM/2022[2016-17]Status: DisposedITAT Mumbai21 Oct 2022AY 2016-17

Bench: Shri Aby T Varkey & Shri Amarjit Singhsumer Nagar Co- Vs. Income-Tax Officer, Ward Operative Housing 32(3)(4), Mumbai Society Limited, Bldg. Kautilya Bhavan, Bkc No.1, Ground Floor, Complex Bandra East, Office Of Sumer Nagar Mumbai - 400051 Bldg No. 1. S.V. Road, Near Flyover, Borivali (W) Mumbai – 400 092 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aacas6832K Appellant .. Respondent

For Appellant: Jitendra SinghFor Respondent: Mahita Nair
Section 143(2)Section 143(3)Section 144Section 80PSection 80P(2)(d)

…Sec. 80P(2)(d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may herein observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co- operative 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…

Alka Co-Operative Housing Society Limited, Mumbai vs. Ward 24(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1236/MUM/2022[2018-2019]Status: DisposedITAT Mumbai21 Oct 2022AY 2018-2019

Bench: Shri Aby T Varkey & Shri Amarjit Singhalka Co-Operative Vs. Ward 24(1)(1) Housing Society Limited Piramal Chamber, Plot No. 296A Shivaji Lalbaug, Parel, Colony, Off Andheri Mumbai - 400012 Kurla Road, Chakrala Andheri East – 400099 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aacaa9218R Appellant .. Respondent

For Appellant: Hemant SinghFor Respondent: Mahita Nair
Section 119Section 119(2)(b)Section 139Section 143Section 154Section 80P(2)(d)

…Sec. 80P(2)(d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may herein observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co- operative 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…

M/S. Bhavasar Kshatriya Co-Operative Credit Society Limited, Hubballi vs. Assistant Director of Income Tax, CPC, Bangalore

In the result, all the three appeals filed by assessee stands allowed for statistical purposes

ITA 583/BANG/2022[2019-20]Status: DisposedITAT Bangalore19 Oct 2022AY 2019-20

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Appeal No. Appellant Respondent Year The Income-Tax

For Appellant: Smt. Pratibha, Advocate
Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

…mutuality by dealing with nominal members, and hence, was not entitled to the benefit of mutuality. The Ld.DR also relied on a subsequent decision of the Hon'ble Karnataka High Court in the case of PCIT Vs. Totgars Co- operative Sale Society Ltd., reported in 395 ITR 611. 2.6. We have heard both sides in light of records placed before us. The Ld.AO denied the claim of the assessee on the ground that interest income earned by making investment of surplus funds has to be assessed under the head "Income from Other Sources" and not income from business and since interest income is not assessed as business income, the…

M/S. Bhavasar Kshatriya Co-Operative Credit Society Limited, Hubballi vs. Income Tax Officer Ward-1(1), Hubballi

In the result, all the three appeals filed by assessee stands allowed for statistical purposes

ITA 582/BANG/2022[2017-18]Status: DisposedITAT Bangalore19 Oct 2022AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Appeal No. Appellant Respondent Year The Income-Tax

For Appellant: Smt. Pratibha, Advocate
Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

…mutuality by dealing with nominal members, and hence, was not entitled to the benefit of mutuality. The Ld.DR also relied on a subsequent decision of the Hon'ble Karnataka High Court in the case of PCIT Vs. Totgars Co- operative Sale Society Ltd., reported in 395 ITR 611. 2.6. We have heard both sides in light of records placed before us. The Ld.AO denied the claim of the assessee on the ground that interest income earned by making investment of surplus funds has to be assessed under the head "Income from Other Sources" and not income from business and since interest income is not assessed as business income, the…

M/S. Bhavasar Kshatriya Co-Operative Credit Society Limited, Hubballi vs. Income Tax Officer Ward-3(3), Hubballi

In the result, all the three appeals filed by assessee stands allowed for statistical purposes

ITA 581/BANG/2022[2015-16]Status: DisposedITAT Bangalore19 Oct 2022AY 2015-16

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Appeal No. Appellant Respondent Year The Income-Tax

For Appellant: Smt. Pratibha, Advocate
Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

…mutuality by dealing with nominal members, and hence, was not entitled to the benefit of mutuality. The Ld.DR also relied on a subsequent decision of the Hon'ble Karnataka High Court in the case of PCIT Vs. Totgars Co- operative Sale Society Ltd., reported in 395 ITR 611. 2.6. We have heard both sides in light of records placed before us. The Ld.AO denied the claim of the assessee on the ground that interest income earned by making investment of surplus funds has to be assessed under the head "Income from Other Sources" and not income from business and since interest income is not assessed as business income, the…

Vijay Gramin Bigarseti Sah Patsanstha Maryadit, Satara, Phaltan vs. Principal Commissioner of Income-Tax -3, Pune

Appeal is allowed in above terms

ITA 201/PUN/2022[2017-18]Status: DisposedITAT Pune10 Oct 2022AY 2017-18

Bench: Shri S.S.Godara, Jm & Shri G.D. Padmahshali, Am आयकर अपील सं. / Ita No.201/Pun/2022 धनधाारण वषा / Assessment Year : 2017-18

For Appellant: Shri M.K.KulkarniFor Respondent: Shri Sardar Singh Meena
Section 143(3)Section 263Section 80PSection 80P(2)(d)

…par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Although, in all fairness, we may herein observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative Sale Society (2017) 395 ITR 611 (Karn), as had been relied upon by the ld. D.R before us, had held, that a co- operative society would not be entitled to claim deduction under Sec. 80P(2)(d); but then, the Hon'ble High Court in the case of Pr. 9 A.Y. : 2017-18 Vijay Gramin Bigarseti Sahakari Patsanstha Maryadit, Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sal…

Avanti Niketan Co-Operative Housing Society Ltd, Mumbai vs. Commissioner of Income Tax (Appeal), Mumbai

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

ITA 1851/MUM/2022[2020-2021]Status: DisposedITAT Mumbai06 Oct 2022AY 2020-2021
Section 80PSection 80P(2)(d)

…had set aside the issue to the file of the assessing officer for fresh examination. That as regards the reliance placed by the ld. D.R on the judgment of the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative Sale Society (2017) 395 ITR 611 (Karn), the High Court had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-ju…

Parle Geeta Coop Hsg SC Ltd, Mumbai vs. CPC Unit, Bangalore

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

ITA 2152/MUM/2022[2016-17]Status: DisposedITAT Mumbai30 Sept 2022AY 2016-17

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: NoneFor Respondent: Shri Manoj Sinha
Section 143(3)Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…had set aside the issue to the file of the assessing officer for fresh examination. That as regards the reliance placed by the ld. D.R on the judgment of the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative Sale Society (2017) 395 ITR 611 (Karn), the High Court had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-ju…

ITO WD 12(3)(1), Mumbai vs. M/S. Mittal Court Premises Co-Op Society Ltd., Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 2128/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Sept 2022AY 2018-19

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: NoneFor Respondent: Shri Manoj Sinha
Section 194Section 194ASection 80PSection 80P(2)(d)Section 80P(4)

…had set aside the issue to the file of the assessing officer for fresh examination. That as regards the reliance placed by the ld. D.R on the judgment of the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative Sale Society (2017) 395 ITR 611 (Karn), the High Court had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-ju…

Samarpan A & B Wing Co Operative Housing Society Limited, Mumbai vs. Income Tax Officer 32(2)(1), Mumbai

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

ITA 2121/MUM/2022[2020-21]Status: DisposedITAT Mumbai30 Sept 2022AY 2020-21

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: NoneFor Respondent: Shri Manoj Sinha
Section 143(1)(a)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…had set aside the issue to the file of the assessing officer for fresh examination. That as regards the reliance placed by the ld. D.R on the judgment of the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative Sale Society (2017) 395 ITR 611 (Karn), the High Court had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-ju…

Tridev I Co Op Hsg Soc Ltd, Mumbai vs. ITO, Ward 26(3)(6), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2112/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Sept 2022AY 2017-18

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: NoneFor Respondent: Shri Manoj Sinha
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…had set aside the issue to the file of the assessing officer for fresh examination. That as regards the reliance placed by the ld. D.R on the judgment of the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative Sale Society (2017) 395 ITR 611 (Karn), the High Court had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-ju…

Shree Rangdas Swami Sahakari Patpedhi Maryadit, Mumbai vs. ITO 27 (3)(3), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2084/MUM/2022[2010-11]Status: DisposedITAT Mumbai30 Sept 2022AY 2010-11

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: NoneFor Respondent: Shri Manoj Sinha
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…had set aside the issue to the file of the assessing officer for fresh examination. That as regards the reliance placed by the ld. D.R on the judgment of the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative Sale Society (2017) 395 ITR 611 (Karn), the High Court had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-ju…

Bhag Coop Housing Society Ltd, Mumbai vs. Asstt Commissioner of Income Tax-CPC-Bengaluru, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 1972/MUM/2022[2020-21]Status: DisposedITAT Mumbai30 Sept 2022AY 2020-21

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: NoneFor Respondent: Shri Manoj Sinha
Section 143(3)Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

…had set aside the issue to the file of the assessing officer for fresh examination. That as regards the reliance placed by the ld. D.R on the judgment of the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative Sale Society (2017) 395 ITR 611 (Karn), the High Court had concluded that a co-operative society would not be entitled to claim of deduction under Sec. 80P(2)(d). We however find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-ju…

Shree Kulswamini Co.Op.Credit Society Ltd, Mumbai vs. ITO WD-28(3) (2), Navi Mumbai

ITA 730/MUM/2022[2017-18]Status: DisposedITAT Mumbai29 Sept 2022AY 2017-18

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2017-18 & Assessment Year: 2018-19

For Appellant: NoneFor Respondent: Shri Soumendu Kumar Dash, D.R
Section 143(3)Section 56CSection 80PSection 80P(2)Section 80P(2)(d)

…r Sec. 80P(2)(d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may herein observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative 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 Kulswami Co-Op.Credit Society Ltd, Navi Mumbai vs. ITO WD-28(3) (2), Mumbai

ITA 729/MUM/2022[2018-19]Status: DisposedITAT Mumbai29 Sept 2022AY 2018-19

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2017-18 & Assessment Year: 2018-19

For Appellant: NoneFor Respondent: Shri Soumendu Kumar Dash, D.R
Section 143(3)Section 56CSection 80PSection 80P(2)Section 80P(2)(d)

…r Sec. 80P(2)(d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may herein observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative 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…

Palm Court M Premises Co Operative Society Ltd., Mumbai vs. Pr. CIT - 30, Mumbai

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

ITA 561/MUM/2021[2015-16]Status: DisposedITAT Mumbai09 Sept 2022AY 2015-16

Bench: Shri Amarjit Singh () & Smt. Kavitha Rajagopal ()

Section 143(3)Section 263Section 40Section 80P(2)(d)

…r Sec. 80P(2)(d) on the interest income on the investments/deposits parked with a co-operative bank. Although, in all fairness, we may herein observe that the Hon'ble High Court of Karnataka in the case of Pr. CIT Vs. Totagars co-operative 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…