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

392 ITR 74High Court2017#67 most cited

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.

762

judgments rely on this decision, according to BharatTax’s citation analysis of 383,853 Indian tax judgments — from 2017 to 2026.

Also referred to as

Pr. CIT v. Totagars Cooperative Sale Society · 392 ITR 74 · Section 80P(2)(d) · Section 80P · cooperative society deduction · interest income cooperative bank · eligibility deduction · income of co-operative societies · cooperative bank interest · investment income

Sections most often in play

Section 80P(2)(d)Section 80P(4)Section 80P(2)(a)(i)Section 143(3)Section 2(19)Section 250Section 80PSection 143(1)

Issues it is cited on

section 56(i)(ccv)section 80(2)(d)section 2(19)section 80(p)(2)(a)section 80p(4)section 80p(1)section 80p(2)(c)section 80(p)(2)(d)section 80p(2)(a)(iii)section 80p(2)(d)section 70section 80p(2)

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

Pune Zilla Sahakari Dudh Utpadak Sangh Maryadit, Pune vs. DCIT, Circle-5, Pune

In the result, appeal of the Assessee for A

ITA 2195/PUN/2025[2018-19]Status: DisposedITAT Pune08 Jan 2026AY 2018-19

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2194 & 2195/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Pune Zilla Sahakari Dudh V Dcit, Utpadak Sangh Maryadit, S. Circle-5, Pune. Katraj Dairy, Pune Satara Road, Katraj, Pune – 411037. Pan: Aaaap0836A Appellant/ Assessee Respondent / Revenue Assessee By Shri M.R.Bhagwat Revenue By Smt. Saumya Pandey Jain – Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 30.07.2025 Emanating From The Separate Assessment Orders Under Section 143(3) Of The Act, 1961 Dated 19.12.2019 & 19.01.2021 For The A.Y.2017-18 & 2018-19 Respectively. For The Sake Of Convenience, Both The Appeals Were Heard Together & Decided In A

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

…derived 4 ITA Nos.2194 & 2195/PUN/2025 [A] by the co-operative society from its investments with any other co-operative society, the whole of such income; 9. The Hon’ble Karnataka High Court in the case of PCIT Vs. Totagar’s Co-operative Sale Society Ltd., 392 ITR 74 [2017] dated 05.01.2017 has held as under : Quote.”2. Briefly the facts of the case are that the respondent assessee is a Co-operative Credit Society providing credit facilities to its members, and marketing the agricultural produce of its members; it runs a kirana section, rice mills, van section, medical shop, Arecanut trading section, lodging i…

Pune Zilla Sahakari Dudh Utpadak Sangh Maryadit, Pune vs. DCIT, Circle-5, Pune

In the result, appeal of the Assessee for A

ITA 2194/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2194 & 2195/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Pune Zilla Sahakari Dudh V Dcit, Utpadak Sangh Maryadit, S. Circle-5, Pune. Katraj Dairy, Pune Satara Road, Katraj, Pune – 411037. Pan: Aaaap0836A Appellant/ Assessee Respondent / Revenue Assessee By Shri M.R.Bhagwat Revenue By Smt. Saumya Pandey Jain – Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 30.07.2025 Emanating From The Separate Assessment Orders Under Section 143(3) Of The Act, 1961 Dated 19.12.2019 & 19.01.2021 For The A.Y.2017-18 & 2018-19 Respectively. For The Sake Of Convenience, Both The Appeals Were Heard Together & Decided In A

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

…derived 4 ITA Nos.2194 & 2195/PUN/2025 [A] by the co-operative society from its investments with any other co-operative society, the whole of such income; 9. The Hon’ble Karnataka High Court in the case of PCIT Vs. Totagar’s Co-operative Sale Society Ltd., 392 ITR 74 [2017] dated 05.01.2017 has held as under : Quote.”2. Briefly the facts of the case are that the respondent assessee is a Co-operative Credit Society providing credit facilities to its members, and marketing the agricultural produce of its members; it runs a kirana section, rice mills, van section, medical shop, Arecanut trading section, lodging i…

Sri Gangadhareshwara Souhardha Pattina Sahakari Sangha Niyamitha, Koppal vs. ITO Ward - 1 Koppal, Koppal

ITA 1775/BANG/2025[2018-19]Status: DisposedITAT Bangalore08 Jan 2026AY 2018-19

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year :2018-19

For Appellant: Shri Deepak, CAFor Respondent: Shri Subramanian – JCIT DR
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ncome-tax officer Word-V, Tumkur [2015] 55 taxmann.com 447 (Karnataka)/[2015] 230 Taxman 309 (Karnataka)[28-10-2014] and in case of Principal Commissioner of Income-tax, Hubli vs. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169 (Karnataka)/[2017] 392 ITR 74 (Karnataka)[05-01-2017has allowed the deduction to the Assessee u/s. 80P(2)(a)(i) of the Act. The decision of Hon’ble Supreme Court in 188 taxmann.com 282 was considered by both the above decisions of the Hon’ble Karnataka High Court. Thus, apparently the claim of the Assessee is covered by the above two decisions. Furthermore, the decision of the…

Sterling Court F Wing Co Op Housing Society Limited, Mumbai vs. Income Tax Officer Ward 31(2)(1), Mumbai

ITA 7122/MUM/2025[2014-15]Status: DisposedITAT Mumbai08 Jan 2026AY 2014-15

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Vijay Shah, ARFor Respondent: Assessee by
Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 80ASection 80A(5)Section 80PSection 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 v/s 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 from a Co-operative Society Bank would be deductible 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…

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

…. Further the Page 10 of 14 decision of the Hon’ble Supreme Court was also considered in paragraph no 9 of the decision. 15. In Principal Commissioner of Income-tax, Hubli vs. Totagars Co- operative Sale Society [2017] 78 taxmann.com 169 (Karnataka)/ [2017] 392 ITR 74 (Karnataka) [05-01-2017] it is held that: 7. However, the contention being taken by the learned counsel is untenable. For the issue that was before the ITAT, was a limited one, namely whether for the purpose of Section 80P(2)(d) of the Act, a Co- operative Bank should be considered as a Co-operative Society or not? For, if a Co-operative Bank is…

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)

…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.…

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

…the assessee. Further the decision of the honourable Supreme Court was also considered in paragraph no 9 of the decision. 15. In Principal Commissioner of Income-tax, Hubli vs. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169 (Karnataka)/ [2017] 392 ITR 74 (Karnataka) [05-01-2017] it is held that: 7. However, the contention being taken by the learned counsel is untenable. For the issue that was before the ITAT, was a limited one, namely whether for the purpose of Section 80P(2)(d) of the Act, a Co- operative Bank should be considered as a Co-operative Society or not? Page 13 of 16 For, if a Co-ope…

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

…the assessee. Further the decision of the honourable Supreme Court was also considered in paragraph no 9 of the decision. 15. In Principal Commissioner of Income-tax, Hubli vs. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169 (Karnataka)/ [2017] 392 ITR 74 (Karnataka) [05-01-2017] it is held that: 7. However, the contention being taken by the learned counsel is untenable. For the issue that was before the ITAT, was a limited one, namely whether for the purpose of Section 80P(2)(d) of the Act, a Co- operative Bank should be considered as a Co-operative Society or not? Page 13 of 16 For, if a Co-ope…

Deepalaxmi Nagari Patsanstha Maryadit, Sangamnagar vs. ITO Ward 2, Aurangabad

ITA 2323/PUN/2024[2020-21]Status: DisposedITAT Pune19 Dec 2025AY 2020-21

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Panda

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri A D Kulkarni
Section 142(1)Section 143(2)Section 56Section 80PSection 80P(1)(a)Section 80P(2)Section 80P(2)(a)Section 80P(2)(c)

…ari Patpedhi Maryadit Vs. ITO - 83 taxmann.com 247 (Mumbai - Trib.) The MES Employees Co-op Credit Society Ltd. Vs. ITO vide ITA i. No.2531/PUN/2024 order dated 20.03.2025 Cases wherein deduction u/s 80P(2)(d) allowed a. PCIT Vs. Totagars Co-op Sale Society - 392 ITR 74 (Karnataka) b. Mantola Co-op Thrift & Credit Society Ltd. Vs. ITO 118 taxmann.com 276 (Delhi - Trib.) c. Shree Mahadeshwar Sah. Patpedhi Maryadit Vs. ITO -374/MUM/2018 d. Sai Prerna Co-op Society Ltd. Vs. ITO - ITA No. 5741/MUM/2018 e. Siemens Employees Co-op Credit Society Ltd. Vs. ITO ITA No. 2237/MUM/2017 f. Kaliandas Udyog Bhavan Premises Co-o…

Deepalaxmi Nagari Patsanstha Maryadit, Sangamnagar vs. ITO Ward 2, Ahmednagar

ITA 2322/PUN/2024[2018-19]Status: DisposedITAT Pune19 Dec 2025AY 2018-19

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Panda

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri A D Kulkarni
Section 142(1)Section 143(2)Section 56Section 80PSection 80P(1)(a)Section 80P(2)Section 80P(2)(a)Section 80P(2)(c)

…ari Patpedhi Maryadit Vs. ITO - 83 taxmann.com 247 (Mumbai - Trib.) The MES Employees Co-op Credit Society Ltd. Vs. ITO vide ITA i. No.2531/PUN/2024 order dated 20.03.2025 Cases wherein deduction u/s 80P(2)(d) allowed a. PCIT Vs. Totagars Co-op Sale Society - 392 ITR 74 (Karnataka) b. Mantola Co-op Thrift & Credit Society Ltd. Vs. ITO 118 taxmann.com 276 (Delhi - Trib.) c. Shree Mahadeshwar Sah. Patpedhi Maryadit Vs. ITO -374/MUM/2018 d. Sai Prerna Co-op Society Ltd. Vs. ITO - ITA No. 5741/MUM/2018 e. Siemens Employees Co-op Credit Society Ltd. Vs. ITO ITA No. 2237/MUM/2017 f. Kaliandas Udyog Bhavan Premises Co-o…

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)

…bank, instead of keeping it in hand. The provisions of the I.T. Act cannot be seen as intended to discourage prudent financial conduct on the part of an assessee." F. The Hon'ble Karnataka High court in the case of PCIT vs. Totagars Co- operative Sale Society 392 ITR 74 has held that for the purpose of section 80P(2)(d) of the Act, Co-operative Bank should be considered as cooperative 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 C…

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)

…bank, instead of keeping it in hand. The provisions of the I.T. Act cannot be seen as intended to discourage prudent financial conduct on the part of an assessee." F. The Hon'ble Karnataka High court in the case of PCIT vs. Totagars Co- operative Sale Society 392 ITR 74 has held that for the purpose of section 80P(2)(d) of the Act, Co-operative Bank should be considered as cooperative 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 C…

Bongaon Co-Operative Credit Society Limited, Bongaon vs. DCIT, Circle 32, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1371/KOL/2025[2022-2023]Status: DisposedITAT Kolkata18 Dec 2025AY 2022-2023

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2022-23 Bongaon Cooperative Credit Society Ltd..…………….……….……….……Appellant First Floor, Banerjee Market Jessore Road, Bongaon, Dist: North 24 Parganas, W.B - 743235.. [Pan: Aaaab6325N] Vs. Dcit, Circle-32, Kolkata….…………...…………………….....……...…..…..Respondent Appearances By: S. Ghosh, Ca, Appeared On Behalf Of The Appellant. Ruchika Sharma, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Year Under Consideration On 28.08.2022 Declaring Nil Income After Claiming Deduction U/S 80P Of The Act Of Rs.25,75,431.98/- . The Case Of The Assessee Was Selected For Scrutiny Through Cass. The Assessment Was Completed Vide Order U/S 143(3) R.W.S. 144B Of The Act Dated 15.03.2024 Determining Total Income At Rs.71,81,740/- By Disallowing Deduction U/S 80P Of The Act With Regard To The Interest Income Received From Banks. Bongaon Cooperative Credit Society Ltd 3. Aggrieved By The Said Order, The Assessee Preferred Appeal Before The Ld. Cit(A) Wherein The Appeal Of The Assessee Has Been Dismissed.

Section 143(3)Section 250Section 68Section 80PSection 80P(2)(d)

…on 80P(2)(d): 3 Bongaon Cooperative Credit Society Ltd (i) Thorapadi Urban Co-op Credit Society Ltd. Vs. Income Tax Officer reported in 296 Taxman 250 (Madras) (ii) Principal Commissioner of Income Tax, Hubli Vs. Totagars Co-operative Sale Society reported in 392 ITR 74 (Karnataka). Considering this discussion, the action of Ld. CIT(A) is upheld on this point also. In result, the Revenue’s appeal fails on this point too.” 7. Considering the above discussion and following the decision of the Coordinate Bench of the Tribunal in assessee’s own case under similar circumstances, we allow the claim of deduction u/s 80P…

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)

…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, 8 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…

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)

…o the assessee. Further the decision of the honourable Supreme Court was also considered in paragraph no 9 of the decision. 12. In Principal Commissioner of Income-tax, Hubli vs. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169 (Karnataka)/ [2017] 392 ITR 74 (Karnataka) [05-01-2017] it is held that: 7. However, the contention being taken by the learned counsel is untenable. For the issue that was before the ITAT, was a limited one, namely whether for the purpose of Section 80P(2)(d) of the Act, a Co-operative Bank should be considered as a Co-operative Society or not? For, if a Co-operative Bank is co…

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)

…o the assessee. Further the decision of the honourable Supreme Court was also considered in paragraph no 9 of the decision. 11. In Principal Commissioner of Income-tax, Hubli vs. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169 (Karnataka)/ [2017] 392 ITR 74 (Karnataka) [05-01-2017] it is held that: 7. However, the contention being taken by the learned counsel is untenable. For the issue that was before the ITAT, was a limited one, namely whether for the purpose of Section 80P(2)(d) of the Act, a Co-operative Bank should be considered as a Co-operative Society or not? For, if a Co-operative Bank is co…

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

…o the assessee. Further the decision of the honourable supreme court was also considered in paragraph no 9 of the decision. 21. In Principal Commissioner of Income-tax, Hubli vs. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169 (Karnataka)/ [2017] 392 ITR 74 (Karnataka) [05-01-2017] it is held that: 7. However, the contention being taken by the learned counsel is untenable. For the issue that was before the ITAT, was a limited one, namely whether for the purpose of Section 80P(2)(d) of the Act, a Co-operative Bank should be considered as a Co-operative Society or not? For, if a Co-operative Bank is co…

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

…o the assessee. Further the decision of the honourable supreme court was also considered in paragraph no 9 of the decision. 21. In Principal Commissioner of Income-tax, Hubli vs. Totagars Co-operative Sale Society [2017] 78 taxmann.com 169 (Karnataka)/ [2017] 392 ITR 74 (Karnataka) [05-01-2017] it is held that: 7. However, the contention being taken by the learned counsel is untenable. For the issue that was before the ITAT, was a limited one, namely whether for the purpose of Section 80P(2)(d) of the Act, a Co-operative Bank should be considered as a Co-operative Society or not? For, if a Co-operative Bank is co…

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)

…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, 8 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…

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)

…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 8 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.…