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 367,154 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

Shri Basaveshwar Urban Co Operative Credit Society Limited, Belagavi vs. Income Tax Officer National E Assessment Centre, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 179/PAN/2024[2018-2019]Status: DisposedITAT Panaji28 Nov 2025AY 2018-2019

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Kumta Adike Marata Sopuharda Sahakari Sangh Niyamit, Kumta vs. Income Tax Officer, Ward - 2, Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 153/PAN/2024[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Samarth Urban Co-Operative Credit Society Ltd, Belgaum vs. Pr. Commissioner of Income Tax, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 152/PAN/2024[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Samarth Urban Co-Operative Credit Society Ltd, Belgaum vs. Pr Commissioner of Income Tax, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 151/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Shri Shradha Credit Souhard Sahakari Niymit Nipani, Nipani vs. ITO, Ward-2 Belgaum, Belgaum

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 144/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Shivagiri Co-Op Credit Society Ltd, Belagavi vs. Income Tax Officer, Ward - 1(3), Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 138/PAN/2024[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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 Mahila Credit Souhard Sahakari Sangh Niyamit, Belagavi vs. ITO Ward 1 Belagavi, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 117/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 161/PAN/2023[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 160/PAN/2023[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 159/PAN/2023[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 158/PAN/2023[2014-15]Status: DisposedITAT Panaji28 Nov 2025AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

…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…

Income Tax Officer, Ward 2, Ahmednagar vs. Kanifnath Grmain Bigar Sheti Sahakari Patsanstha Maryadit, Malad

In the result, appeal of the Revenue is dismissed

ITA 2272/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2272/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakari Patsanstha Maryadit, At Post Maldad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant / Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte Revenue By Shri Arvind Renge –Addl.Cit(Virtual Hearing) Date Of Hearing 04/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 01.07.2025, Emanating From Order U/S.143(3) R.W.S144B Of The Income Tax Act, 1961, Dated 22.09.2022. The Revenue Has Raised The Following Concise Grounds Of Appeal :

Section 143(3)Section 250Section 80P(2)(d)

…w, the Ld. CIT Appeal erred in deduction us 80P(2)(d) of the Income Tax Act of Rs.2,19,34,691 without considering the decision of Honble High Court of Karnataka in the case of Principal commissioner of Income Tax, Huballi vs. Totgars co-operative Sale society 395 ITR 611, dated 16.06.2017. On the facts and the circumstances of the case and in law, the Ld. CIT Appeal erred in allowing the deduction us 80P2d of the LT.Act without proper verification of the facts as to how the investments made by the assessee with other co operative banks generated the operational income of the assessee, considering the facts that t…

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara

In the result, the appeal of the assessee is allowed for statistical

ITA 2156/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara Pan: Aaaat1502B अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)

…HC decision in the case of Totgar's Co-operative sale society 392 ITR 74 and argue that it is held in this decision that a co-operative bank is considered to be a co-operative society. However, the Hon'ble HC in the later decision in the same case reported in 395 ITR 611 has clearly held that what Section 80P(2)(d) of the Act envisages is that such interest or dividend earned by an assessee co-operative society should be out of the investments with any other co-operative society. 5.6 The words 'Co-operative Banks' are missing in clause (d) of subsection (2) of Section 80P of the Act. Even though a co-operative ba…

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara

In the result, the appeal of the assessee is allowed for statistical

ITA 2155/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Pan: Aaaat1502B अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara प्रत्यर्थी / Respondent Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)

…HC decision in the case of Totgar's Co-operative sale society 392 ITR 74 and argue that it is held in this decision that a co-operative bank is considered to be a co-operative society. However, the Hon'ble HC in the later decision in the same case reported in 395 ITR 611 has clearly held that what Section 80P(2)(d) of the Act envisages is that such interest or dividend earned by an assessee co-operative society should be out of the investments with any other co-operative society. 5.6 The words 'Co-operative Banks' are missing in clause (d) of subsection (2) of Section 80P of the Act. Even though a co-operative ba…

Sugarcane Producers Vividha Karyakari Sahakari Society Ltd, Malsiras vs. ITO Ward 2 Pandharpur, Pandharpur

In the result, appeal of the assessee is partly allowed

ITA 1174/PUN/2025[2017-2018]Status: DisposedITAT Pune28 Nov 2025AY 2017-2018

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1174/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Sugarcane Producers Vividha V The Income Tax Officer, Karyakari Sahakari Society S Ward-2, Pandharpur. Limited, At Post Malinagar, Malsiras, District Solapur, Solapur – 413108. Maharashtra. Pan: Aaffs4023E Appellant/ Assessee Respondent / Revenue Assessee By Shri Girish Ladda Revenue By Shri Ambarnath Khule (Through Virtual) – Jcit(Dr) Date Of Hearing 24/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Additional Commissioner Of Income Tax(Appeal)-1, Visakhapatnam Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2017-18 On 10.03.2025 Emanating From Assessment Order U/S.143(3) R.W.S 147 Dated 24.12.2019. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 250Section 80PSection 80P(2)Section 80P(2)(a)

…s.80P(2)(a)(i) on the interest earned. The Hon’ble Andhra Pradesh 6 ITA No.1174/PUN/2025 [A] High Court has distinguished the decision of Hon’ble Supreme Court in the case of Principal commissioner of Income Tax, Huballi vs. Totgars co-operative Sale society 395 ITR 611, dated 16.06.2017. 8.2 The Hon’ble Kerala High Court in the case of Pr.CIT Vs. Sahyadri Co-operative Credit Society Ltd., [2024] 301 Taxman 36 (Kerala) vide order dated 04.09.2024, has held as under : Quote “7. On a consideration of the rival submissions, we are of the view that for the reasons stated hereinafter, the question of law that arises…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2405/CHNY/2025[2018-19]Status: DisposedITAT Chennai28 Nov 2025AY 2018-19

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

…assessee society from such a co-operative bank is not entitled for deduction u/s.80P(2)(d) of the Act. Further, the Ld.DR relied on the judgment of the Hon’ble Karnataka High Court in the case of PCIT vs. Totagars Co- operative Sale Society reported in [2017] 395 ITR 611. 6. The Ld.AR on the other hand submitted that the issue in question is squarely covered in favour of the assessee by the judgment of the Hon’ble Jurisdictional High Court in the case of Thorapadi Urban Co-op Credit Society Ltd., Virupachipuram Urban Co-op Credit Society Ltd., supra and the order of the Tribunal in assessee’s own case for the ass…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2404/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Nov 2025AY 2017-18

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

…assessee society from such a co-operative bank is not entitled for deduction u/s.80P(2)(d) of the Act. Further, the Ld.DR relied on the judgment of the Hon’ble Karnataka High Court in the case of PCIT vs. Totagars Co- operative Sale Society reported in [2017] 395 ITR 611. 6. The Ld.AR on the other hand submitted that the issue in question is squarely covered in favour of the assessee by the judgment of the Hon’ble Jurisdictional High Court in the case of Thorapadi Urban Co-op Credit Society Ltd., Virupachipuram Urban Co-op Credit Society Ltd., supra and the order of the Tribunal in assessee’s own case for the ass…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2403/CHNY/2025[2016-17]Status: DisposedITAT Chennai28 Nov 2025AY 2016-17

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

…assessee society from such a co-operative bank is not entitled for deduction u/s.80P(2)(d) of the Act. Further, the Ld.DR relied on the judgment of the Hon’ble Karnataka High Court in the case of PCIT vs. Totagars Co- operative Sale Society reported in [2017] 395 ITR 611. 6. The Ld.AR on the other hand submitted that the issue in question is squarely covered in favour of the assessee by the judgment of the Hon’ble Jurisdictional High Court in the case of Thorapadi Urban Co-op Credit Society Ltd., Virupachipuram Urban Co-op Credit Society Ltd., supra and the order of the Tribunal in assessee’s own case for the ass…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2402/CHNY/2025[2014-15]Status: DisposedITAT Chennai28 Nov 2025AY 2014-15

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2401, 2402, 2403, 2404 & 2405/Chny/2025 निर्धारण वर्ष/Assessment Years: 2013-14, 2014-15, 2016-17, 2017-18 & 2018-19 The Assistant Commissioner Of Income Tax, Circle-1, Cuddalore M/S. Kallakurichi-Ii Co- Vs. Operative Sugar Mills Ltd., A1, Kachirapalayam, Kallakurichi, Cuddalore - 606 207 (अपीलार्थी/Appellant) Pan: Aaaak 0655Q (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Ms. E. Pavuna Sundari, Cit प्रत्यर्थी की ओर से/Respondent By : Shri S. Venugopalan, Ca सुनवाई की तारीख/Date Of Hearing : 27.11.2025 घोषणा की तारीख/Date Of Pronouncement : 28.11.2025 आदेश/Order Per George George K: These Appeals Filed By The Revenue Are Directed Against The Five Separate Orders Of The Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi, All Dated 18.06.2025, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant Assessment Years Are 2013-14, 2014-15 & 2016-17 To 2018-19. 2. The Solitary Issue That Is Raised Is Whether The First Appellate Authority (Faa) Is Justified In Directing The Ao To Grant Deduction U/S.80P(2)(D) Of The Act On The Interest Income Received By The Assessee From Villupuram District Central Co- Operative Bank. 3. Brief Facts Of The Case Are As Follows: The Assessments Were Completed U/S.147 R.W.S.144 R.W.S.144B Of The Act For The

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80P(2)(a)Section 80P(2)(d)

…assessee society from such a co-operative bank is not entitled for deduction u/s.80P(2)(d) of the Act. Further, the Ld.DR relied on the judgment of the Hon'ble Karnataka High Court in the case of PCIT vs. Totagars Co- operative Sale Society reported in [2017] 395 ITR 611. 6. The Ld.AR on the other hand submitted that the issue in question is squarely covered in favour of the assessee by the judgment of the Hon'ble Jurisdictional High Court in the case of Thorapadi Urban Co-op Credit Society Ltd., Virupachipuram Urban Co-op Credit Society Ltd., supra and the order of the Tribunal in assessee's own case for the ass…

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi-II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2401/CHNY/2025[2013-14]Status: DisposedITAT Chennai28 Nov 2025AY 2013-14

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

…assessee society from such a co-operative bank is not entitled for deduction u/s.80P(2)(d) of the Act. Further, the Ld.DR relied on the judgment of the Hon’ble Karnataka High Court in the case of PCIT vs. Totagars Co- operative Sale Society reported in [2017] 395 ITR 611. 6. The Ld.AR on the other hand submitted that the issue in question is squarely covered in favour of the assessee by the judgment of the Hon’ble Jurisdictional High Court in the case of Thorapadi Urban Co-op Credit Society Ltd., Virupachipuram Urban Co-op Credit Society Ltd., supra and the order of the Tribunal in assessee’s own case for the ass…