Which sections of the Income Tax Act does Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society come up under?

It is most often cited in judgments turning on Section 80P(2)(d), Section 80P(4), Section 80P(2)(a)(i), Section 143(3), Section 2(19), Section 250.

Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society (392 ITR 74)

Q: What is Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society authority for?

Interest income earned by a cooperative society from its investments or surplus deposits with a cooperative bank is eligible for deduction under Section 80P(2)(d) of the Income-tax Act, 1961.

Q: How many judgments cite Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society?

762 judgments on BharatTax cite Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society (392 ITR 74), spanning 2017 to 2026.

Om Shivdarshan Co-Op Hosing Society Ltd, Mumbai vs. Income Tax Officer, Ward 41(2)(3), Mumbai

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

ITA 966/MUM/2026[2021-22]Status: DisposedITAT Mumbai27 Mar 2026AY 2021-22

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Ravindra Naik, CAFor Respondent: Shri Pravin Salunkhe, SR. DR

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

…surplus deposits kept with a Co-operative Bank, was not eligible for deduction under section 80P(2)(d) of the Act. We find that in an earlier decision the Hon'ble Karnataka High Court in Pr. CIT v. Totagars Co- operative Sale Society [2017] 78 taxmann.com 169/392 ITR 74 held that according to section 80P(2)(d) of the Act, the amount of interest earned from a Co-operative Society Bank would be deductable from the gross income of the Co-operative Society in order to assess its total income. Thus, there are divergent views of the same Hon'ble High Court on the issue of eligibility of deduction under section 80P(2)(d…

Shri Basaveshwar Souharda Sahakari Sangha Niyamit, Kalloli vs. Income Tax Officer, Ward - 1, Gokak

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

ITA 485/PAN/2025[2022-23]Status: DisposedITAT Panaji17 Mar 2026AY 2022-23

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

…dated 27.09.2017. (iv). Kaliandas Udyog Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.…

Nityanand Nagar Vibhag -IV Cooperative Housing Society Limited, Mumbai vs. ITO Ward 24(3)(1), Mumbai

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

ITA 494/MUM/2026[2021-22]Status: DisposedITAT Mumbai12 Mar 2026AY 2021-22

Bench: Shri Narender Kumar Choudhryshri Girish Agrawal

For Appellant: Revenue byFor Respondent: Shri Pravin Salunkhe (Sr. DR.)

Section 143(1)Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(D)Section 80P(2)(d)

…tive Society, from surplus deposits kept with a Cooperative Bank, was not eligible for deduction under section 80P(2)(d) of the Act. We find that in an earlier decision the Hon’ble Karnataka High Court in Pr.CIT vs. Totagars Co-operative Sales Society, [2017] 392 ITR 74 (Karn.), held that according to section 80P(2)(d) of the Act, the amount of interest earned form a Co-operative Society Bank would be deductible from the gross income of the So- operative Society in order to assess its total income. Thus, there are divergent views of the same Hon’ble High Court on the issue of eligibility of deduction under sectio…

The Camp Multipurpose Primary Agriculture Cooperative Society Limited, Pernem, Goa vs. Income Tax Officer, Ward 2 (1), Panaji, Goa

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

ITA 55/PAN/2026[2016-17]Status: DisposedITAT Panaji11 Mar 2026AY 2016-17

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

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

…dated 27.09.2017. (iv). Kaliandas Udyog Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.…

La Royal Co-Operative Hsg Soc Ltd, Kandivali vs. Assessing Officer, Kautiliya Bhavan

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

ITA 443/MUM/2026[2021-22]Status: DisposedITAT Mumbai11 Mar 2026AY 2021-22

Bench: Shri Narender Kumar Choudhryshri Girish Agrawal

For Appellant: Shri Ganshyamlal Kachhara, LdFor Respondent: Shri Pravin Salunkhe (Sr. DR.)

Section 143(1)Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(D)Section 80P(2)(d)

…tive Society, from surplus deposits kept with a Cooperative Bank, was not eligible for deduction under section 80P(2)(d) of the Act. We find that in an earlier decision the Hon’ble Karnataka High Court in Pr.CIT vs. Totagars Co-operative Sales Society, [2017] 392 ITR 74 (Karn.), held that according to section 80P(2)(d) of the Act, the amount of interest earned form a Co-operative Society Bank would be deductible from the gross income of the So- operative Society in order to assess its total income. Thus, there are divergent views of the same Hon’ble High Court on the issue of eligibility of deduction under sectio…

Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit, Nippani vs. ITO 1 Nippani, Nippani

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

ITA 66/PAN/2026[2013-14]Status: DisposedITAT Panaji10 Mar 2026AY 2013-14

Bench: Shri Pavan Kumar Gadalei T A. Nos.66/Pan/2026 (A.Y. 2013-14 ) Shri Brahmanath Credit Vs I.T.O-Ward-1, Souhard Sahakari Sangh Nemchand Building, . Niyamat, 747,Ashoknagar, 185/C, Chikodi Road, Nippani-591237, Nippani, Karnataka. Belagavi-591237, Karnataka. Pan .No. Aaaas1063Q (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.U.G.Ammangi.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.03.2026 घोषणा की तारीख/Date Of Pronouncement 10.03.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Deduction Of Interest Income From Cooperative Society, Cooperative Banks & Nationalized Banks U/Sec80P(2)(D) Of The Act. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Credit Society & Is Engaged In Activities Of Providing Credit Facilities To Its Members. The Assessee Has Filed The Return Of Income For The A.Y 2013-14 On 2 Ita. No..66/Pan/2026 Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit. 30.09.2013 Disclosing A Total Income Of Rs.Nil After Claiming Deduction Of Rs.78,06,780/- U/Sec 80P(2)(A)(I) Of The Act. Subsequently The Case Was Selected For Scrutiny Under Cass & Order U/Sec143(3) Of The Act Was Passed Disallowing The Claim U/Sec80P(2)(A)(I) Of The Act Of Rs.78,06,780/- & Disallowance U/Sec40(A)(Ia) Of The Act Of Rs.76,274/- & Assessed The Total Income Of Rs.78,83,054/- Vide Order Dated21.07.2021.Aggrived By The Order, On Appeal To The Cit(A), The Appeal Was Partly Allowed & The Assessee Has Preferred Second Appeal Before The Honble Tribunal & Vide By Order

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

…h Credit Souhard Sahakari Sangh Niyamit. Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.…

Shri Mallikarjun Urban Co Operative Credit Society Limited, Belagavi vs. ITO Ward 1 Belgaum, Belgaum

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

ITA 65/PAN/2026[2017-18]Status: DisposedITAT Panaji06 Mar 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

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

…dated 27.09.2017. (iv). Kaliandas Udyog Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.…

Grant Road (W) Omkar Co-Operative Housing Soc Limited, Mumbai vs. ITO 19(1)(1), Mumbai

In the result, this appeal of the assessee is allowed

ITA 259/MUM/2026[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Ashok MehtaFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(1)Section 80Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…14, dated 27.09.2017. (iv). KaliandasUdyogBhavanPemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.…

Income Tax Officer-26(1)(1), Mumbai vs. Reserve Bank Officers Co-Operative Credit Society Ltd., Mumbai

In the result, all the three appeals filed by the Revenue are dismissed

ITA 8190/MUM/2025[2023-24]Status: DisposedITAT Mumbai04 Mar 2026AY 2023-24

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2020-21 & Assessment Year: 2022-23 & Assessment Year: 2023-24 Income Tax Officer- Vs. Reserve Bank Officers Co- 26(1)(1), Mumbai Operative Credit Society Ltd. 3Rd Floor Amar Building, Sir P M Room No.254, 2Nd Floor Kautilya Road Fort, Mumbai-400001 Bhavan, Bkc, Mumbai-400051 Pan: Aaaar2789N (Appellant) (Respondent) Assessee By Shri Mandar Vaidya Department By Shri Annavaram Kosuri, Sr. Dr Date Of Hearing 02.03.2026 Date Of Pronouncement 04.03.2026

Section 143(3)Section 2(19)Section 80PSection 80P(2)(d)Section 80P(4)

…ction. The Assessing Officer also placed reliance on the decision of the Hon’ble Supreme Court in Totagars Co-operative Sale Society Ltd. v. ITO (322 ITR 283) and the judgment of the Hon’ble Karnataka High Court in PCIT v. Totagars Co- operative Sale Society (392 ITR 74). Accordingly, the deduction claimed under section 80P(2)(d) was disallowed and the total income was assessed by bringing the said interest income to tax. 4. Aggrieved, the assessee preferred appeals before the Ld. CIT(A). The Ld. CIT(A), after considering the submissions of the assessee and the judicial precedents relied upon, deleted the disallo…

Income Tax Officer-26(1)(1), Mumbai vs. Reserve Bank Officers Co-Operative Credit Society Ltd., Mumbai

In the result, all the three appeals filed by the Revenue are dismissed

ITA 8189/MUM/2025[2022-23]Status: DisposedITAT Mumbai04 Mar 2026AY 2022-23

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2020-21 & Assessment Year: 2022-23 & Assessment Year: 2023-24 Income Tax Officer- Vs. Reserve Bank Officers Co- 26(1)(1), Mumbai Operative Credit Society Ltd. 3Rd Floor Amar Building, Sir P M Room No.254, 2Nd Floor Kautilya Road Fort, Mumbai-400001 Bhavan, Bkc, Mumbai-400051 Pan: Aaaar2789N (Appellant) (Respondent) Assessee By Shri Mandar Vaidya Department By Shri Annavaram Kosuri, Sr. Dr Date Of Hearing 02.03.2026 Date Of Pronouncement 04.03.2026

Section 143(3)Section 2(19)Section 80PSection 80P(2)(d)Section 80P(4)

…ction. The Assessing Officer also placed reliance on the decision of the Hon’ble Supreme Court in Totagars Co-operative Sale Society Ltd. v. ITO (322 ITR 283) and the judgment of the Hon’ble Karnataka High Court in PCIT v. Totagars Co- operative Sale Society (392 ITR 74). Accordingly, the deduction claimed under section 80P(2)(d) was disallowed and the total income was assessed by bringing the said interest income to tax. 4. Aggrieved, the assessee preferred appeals before the Ld. CIT(A). The Ld. CIT(A), after considering the submissions of the assessee and the judicial precedents relied upon, deleted the disallo…

Income Tax Officer-26(1)(1), Mumbai vs. Reserve Bank Officers Co-Operative Credit Society Ltd., Mumbai

In the result, all the three appeals filed by the Revenue are dismissed

ITA 8188/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Mar 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2020-21 & Assessment Year: 2022-23 & Assessment Year: 2023-24 Income Tax Officer- Vs. Reserve Bank Officers Co- 26(1)(1), Mumbai Operative Credit Society Ltd. 3Rd Floor Amar Building, Sir P M Room No.254, 2Nd Floor Kautilya Road Fort, Mumbai-400001 Bhavan, Bkc, Mumbai-400051 Pan: Aaaar2789N (Appellant) (Respondent) Assessee By Shri Mandar Vaidya Department By Shri Annavaram Kosuri, Sr. Dr Date Of Hearing 02.03.2026 Date Of Pronouncement 04.03.2026

Section 143(3)Section 2(19)Section 80PSection 80P(2)(d)Section 80P(4)

…ction. The Assessing Officer also placed reliance on the decision of the Hon’ble Supreme Court in Totagars Co-operative Sale Society Ltd. v. ITO (322 ITR 283) and the judgment of the Hon’ble Karnataka High Court in PCIT v. Totagars Co- operative Sale Society (392 ITR 74). Accordingly, the deduction claimed under section 80P(2)(d) was disallowed and the total income was assessed by bringing the said interest income to tax. 4. Aggrieved, the assessee preferred appeals before the Ld. CIT(A). The Ld. CIT(A), after considering the submissions of the assessee and the judicial precedents relied upon, deleted the disallo…

Hotel Maleekara Pattina Souharda Sahakaari Sangha Niyamitha, Tumkur vs. Income Tax Officer, Ward-1 & Tps, Tumkur

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

ITA 1110/BANG/2025[2017-18]Status: DisposedITAT Bangalore03 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri A. Shivaram, CA

Section 142(1)Section 143(2)Section 234ASection 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…is also to be treated as profits and gains of business by the assessee society and thereby they are entitled for deduction u/s. 80P(2)(a)(i) or 80P(2)(d) of the Act. We have also perused the judgment of the Hon’ble Jurisdictional High Court reported in (2017) 392 ITR 74 (Karnataka) in the case of PCIT vs. Totagars Co-operative Sales Society in which the Hon’ble High Court has held that a co-operative society / bank would be included in the words “co-operative society” and therefore deduction would be allowed u/s. 80P(2)(d) of the Act on the interest amount earned from the co-operative societies / bank. In the sai…

Shri K.P. Magennavar Laxmi Credit Souharda Sahakari Sangh Ltd.Manjari., Chikodi vs. Income Tax Officer, Ward-1, Nippani

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

ITA 33/PAN/2026[2015-2016]Status: DisposedITAT Panaji27 Feb 2026AY 2015-2016

Bench: Shri Pavan Kumar Gadalei T A. No.33/Pan/2026 (A.Y. 2015-16 ) Shri K.P.Magennavar Laxmi Vs I.T.O-Ward-1, Credit Souharda Sahakari Nemchand Building, . Sangh Limited, 747,Ashoknagar, 521,Laxmibuilding,Mainroad, Nipani-591237, Manjari, Chikodi, Karnataka. Belagavi-591213, Karnataka. Pan .No. Aabas3175N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Jaykumar Patil.Ar Revenue By Smt.Thamba Mahendra.Sr.Dr सुनवाई की तारीख/Date Of Hearing 25.02.2026 घोषणा की तारीख/Date Of Pronouncement 27.02.2026 Order Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of Addl/Jcit(A)-7 Mumbai Passed U/Se 143(3) & U/Sec250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Ac & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act On Interest Income From Cooperative Banks & Scheduled Banks. 2. The Brief Facts Of The Case Are That, The Assessee Souhard Credit Cooperative Society Is Engaged In Providing

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

…dated 27.09.2017. (iv). Kaliandas Udyog Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.…

Valencia Co Operative Housing Society Limited, Mumbai vs. Deputy Commissioner of Income Tax 41(1)(1), Mumbai

Accordingly, Ground No. 1 & 2 raised by the Assessee are allowed

ITA 8366/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Feb 2026AY 2020-21

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER ITA No.8366/MUM/2025 (Assessment Year:2020-2021) Valencia Co. Operative Housing Society Limited Ground Floor, Hiranandani Gardens, Powai, Mumbai - 400076. Maharashtra [PAN: AAAAV0809P] Deputy Commissioner of Income-tax, Circle, 41(1)(1), Mumbai Kautilya Bhavan, Bandra Kurla Complex, Bandra (East), Mumbai - 400051. Maharashtra. Appearance For the Appellant/

For Appellant: Shri Rajeev KhandelwalFor Respondent: Shri Nakul Agrawal

Section 143(1)Section 154Section 80PSection 80P(2)(d)

…operative Housing Society Ltd. Vs. ITORange-20(2)(2), Mumbai (ITA No. 6139/Mum/2014, dated 27.09.2017. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had also held that the interest income earned by the assessee on its investments held with a co- operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14,…

ITO, Mumbai vs. The Jackson Co-Op. Credit Society of the Employee of Western Railway Ltd., Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 5441/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Feb 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Prusethito, Mumbai Vs. The Jackson Co-Op. Society Of The Employee Of Western Railway Ltd. 1, Noushir Bharucha Maro Orant Road, Mumbai – 400007. Pan/Gir No. Aaatt2985P (Applicant) (Respondent)

Section 250Section 801(2)(a)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(ai)

…e case and in the law the Ld.CITA) has erred in allowing the deduction u/s 80P(2)(a)(i) of Rs. 19,77,87,377/-even if Hon'ble Supreme Court as well as Hon'ble Karnataka High Court in the case of Totagar Cooperative sale society (2010) 322 ITR 283(SC) and (2017)392 ITR 74(Kar) held that the income by way of interest earned by deposit or investment of idle or surplus funds does not change its character irrespective of the fact whether such income of interest is earned from a schedule bank or a co-operative bank and thus, clause (d) of section 80P(2) of the Act would not apply in case of co-operative bank? (iv) "Whe…

Horizon Co Operative Housing Society Limited, Mumbai vs. ITO Ward 21(2)(4), Mumbai

In the result, both the appeals filed by the assessee stand allowed

ITA 8469/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Feb 2026AY 2018-19

Bench: Shri Amit Shukla () & Shri Girish Agrawal ()

Section 143(3)Section 2(19)Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…surplus deposits kept with a Co- operative Bank, was not eligible for deduction under section 80P(2)(d) of the Act. We find that in an earlier decision the Hon'ble Karnataka High Court in Pr. CIT v. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169/392 ITR 74 held that according to section 80P(2)(d) of the Act, the amount of interest earned from a Co-operative Society Bank would be deductable from the gross income of the Co- operative Society in order to assess its total income. Thus, there are divergent views of the same Hon'ble High Court on the issue of eligibility of deduction under section 80P(2)(…

Horizon Co-Operative Housing Society Limted, Mumbai vs. ITO Ward 21(1)(4), Mumbai

ITA 8468/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Feb 2026AY 2013-14

Bench: Shri Amit Shukla () & Shri Girish Agrawal () Ι.Τ.Α. Νο. 8468 & 8469/Mum/2025

Section 143(3)Section 2(19)Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…surplus deposits kept with a Co- operative Bank, was not eligible for deduction under section 80P(2)(d) of the Act. We find that in an earlier decision the Hon'ble Karnataka High Court in Pr. CIT v. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169/392 ITR 74 held that according to section 80P(2)(d) of the Act, the amount of interest earned from a Co-operative Society Bank would be deductable from the gross income of the Co- operative Society in order to assess its total income. Thus, there are divergent views of the same Hon'ble High Court on the issue of eligibility of deduction under section 80P(2)(…

Bardc Bank, Bhatkal vs. National E-Assessment Centre, Delhi

In the result, the two appeals filed by the assessee are partly allowed for statistical purposes

ITA 297/PAN/2024[2018-19]Status: DisposedITAT Panaji17 Feb 2026AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.296 & 297/Pan/2024 (A.Y. 2017-18 & 2018-19) Bardc Bank Bhatkal, Ito-Ward-1, Vs Pld Bank, Main Road, Santerikrupa, . Uttara Kannada, Kaigaroad, Bhatkal S.O. Habbuwada, Karnataka-581320. Karwar-581306, Karnataka. Pan .No. Aaaap1731G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

…dated 27.09.2017. (iv). Kaliandas Udyog Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on 11 ITA. No. 296&297/PAN/2024 BARDC Bank. its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we fi…

Bardc Bank, Bhatkal vs. Income Tax Officer, Ward - 1, Karwar

In the result, the two appeals filed by the assessee are partly allowed for statistical purposes

ITA 296/PAN/2024[2017-18]Status: DisposedITAT Panaji17 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.296 & 297/Pan/2024 (A.Y. 2017-18 & 2018-19) Bardc Bank Bhatkal, Ito-Ward-1, Vs Pld Bank, Main Road, Santerikrupa, . Uttara Kannada, Kaigaroad, Bhatkal S.O. Habbuwada, Karnataka-581320. Karwar-581306, Karnataka. Pan .No. Aaaap1731G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

…dated 27.09.2017. (iv). Kaliandas Udyog Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on 11 ITA. No. 296&297/PAN/2024 BARDC Bank. its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we fi…

Shri Hanuman Credit Souharda Sahakari Sangh Ltd, Belagavi vs. Income Tax Officer, Ward - 1, Nippani

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

ITA 235/PAN/2025[2017-18]Status: DisposedITAT Panaji16 Feb 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80P(2)(a)

…dated 27.09.2017. (iv). Kaliandas Udyog Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. We further 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 of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.…

Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society

What is Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society authority for?

Also referred to as

Sections most often in play

Issues it is cited on

Judgments citing Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society

Om Shivdarshan Co-Op Hosing Society Ltd, Mumbai vs. Income Tax Officer, Ward 41(2)(3), Mumbai

Shri Basaveshwar Souharda Sahakari Sangha Niyamit, Kalloli vs. Income Tax Officer, Ward - 1, Gokak

Nityanand Nagar Vibhag -IV Cooperative Housing Society Limited, Mumbai vs. ITO Ward 24(3)(1), Mumbai

The Camp Multipurpose Primary Agriculture Cooperative Society Limited, Pernem, Goa vs. Income Tax Officer, Ward 2 (1), Panaji, Goa

La Royal Co-Operative Hsg Soc Ltd, Kandivali vs. Assessing Officer, Kautiliya Bhavan

Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit, Nippani vs. ITO 1 Nippani, Nippani

Shri Mallikarjun Urban Co Operative Credit Society Limited, Belagavi vs. ITO Ward 1 Belgaum, Belgaum

Grant Road (W) Omkar Co-Operative Housing Soc Limited, Mumbai vs. ITO 19(1)(1), Mumbai

Income Tax Officer-26(1)(1), Mumbai vs. Reserve Bank Officers Co-Operative Credit Society Ltd., Mumbai

Income Tax Officer-26(1)(1), Mumbai vs. Reserve Bank Officers Co-Operative Credit Society Ltd., Mumbai

Income Tax Officer-26(1)(1), Mumbai vs. Reserve Bank Officers Co-Operative Credit Society Ltd., Mumbai

Hotel Maleekara Pattina Souharda Sahakaari Sangha Niyamitha, Tumkur vs. Income Tax Officer, Ward-1 & Tps, Tumkur

Shri K.P. Magennavar Laxmi Credit Souharda Sahakari Sangh Ltd.Manjari., Chikodi vs. Income Tax Officer, Ward-1, Nippani

Valencia Co Operative Housing Society Limited, Mumbai vs. Deputy Commissioner of Income Tax 41(1)(1), Mumbai

ITO, Mumbai vs. The Jackson Co-Op. Credit Society of the Employee of Western Railway Ltd., Mumbai

Horizon Co Operative Housing Society Limited, Mumbai vs. ITO Ward 21(2)(4), Mumbai

Horizon Co-Operative Housing Society Limted, Mumbai vs. ITO Ward 21(1)(4), Mumbai

Bardc Bank, Bhatkal vs. National E-Assessment Centre, Delhi

Bardc Bank, Bhatkal vs. Income Tax Officer, Ward - 1, Karwar

Shri Hanuman Credit Souharda Sahakari Sangh Ltd, Belagavi vs. Income Tax Officer, Ward - 1, Nippani