Sabarkhanta Zilla Kharid Vechan Sangh Ltd. v. ClT

203 ITR 1027Supreme Court of India1993#1156 most cited

What is Sabarkhanta Zilla Kharid Vechan Sangh Ltd. v. ClT authority for?

The Supreme Court holds that deductions under Chapter VI-A, including those under Section 80P, are allowable only on the income included in the gross total income as per the provisions of Section 80AB of the Income-tax Act. This ensures that deductions are calculated on the actual income qualifying for such benefit after all other adjustments.

98

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

Sabarkhanta Zilla Kharid Vechan Sangh Ltd. v. CIT · 203 ITR 1027 (SC) · deductions under Chapter VI-A · Section 80AB · gross total income (GTI) · Section 80P · co-operative society · net income for deduction · calculation of deductions · scope of deductions

Sections most often in play

Section 143(2)Section 14ASection 254(2)Section 80PSection 80P(2)(d)Section 80P(2)(iv)Section 270ASection 8D

Judgments citing Sabarkhanta Zilla Kharid Vechan Sangh Ltd. v. ClT

BARODA DISTRICT COOPERATIVE MILK PRODUCERS UNION LIMITED,VADODARA, GUJARAT vs. ASST. COMMISSIONER OF INCOME TAX OFFICER, CIRCLE 1(1)(1), VADODARA, VADODARA, GUJARAT

In the result, the appeals of the assessee for Asst

ITA 417/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad08 Jul 2025AY 2022-23

Bench: Smt.Annapurna Gupta & Ms.Suchitra R. Kamble

Section 14Section 14ASection 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(2)(iv)

…he Hon’ble Apex Court in the case of Sabarkanta Zilla Kharid Veehan Sangh Ltd.Vs. CIT. Our attention was drawn to the finding of the ld.CIT(A) in this regard at para 5.7 and 5.8 of the order as under: “5.7 In Sabarkanta Zilla Khariod Veehan Sangh Ltd Vs. CIT 203 ITR 1027 (1993), the appellant’s appeals in ITR Nos. 100 of 1974, 24 of 1974 and 139 of 1974 were dismissed by the Hon’ble High Court, Gujarat(The jurisdictional High Court with respect to the appellant in the present appeal)through common judgment dated 03.09.1975. The operative paragraph of the said judgment is being excerpted hereunder: In the light o…

BARODA DISTRICT COOPERATIVE MILK PRODUCERS UNION LIMITED,VADODARA, GUJARAT vs. ASST. COMMISSIONER OF INCOME TAX OFFICER, CIRCLE 1(1)(1), VADODARA, VADODARA, GUJARAT

In the result, the appeals of the assessee for Asst

ITA 416/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad08 Jul 2025AY 2018-19

Bench: Smt.Annapurna Gupta & Ms.Suchitra R. Kamble

Section 14Section 14ASection 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(2)(iv)

…he Hon’ble Apex Court in the case of Sabarkanta Zilla Kharid Veehan Sangh Ltd.Vs. CIT. Our attention was drawn to the finding of the ld.CIT(A) in this regard at para 5.7 and 5.8 of the order as under: “5.7 In Sabarkanta Zilla Khariod Veehan Sangh Ltd Vs. CIT 203 ITR 1027 (1993), the appellant’s appeals in ITR Nos. 100 of 1974, 24 of 1974 and 139 of 1974 were dismissed by the Hon’ble High Court, Gujarat(The jurisdictional High Court with respect to the appellant in the present appeal)through common judgment dated 03.09.1975. The operative paragraph of the said judgment is being excerpted hereunder: In the light o…

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. PEROORKADA SERVICE CO-OPERATIVE BANK LTD

Appeals are allowed as indicated above

ITA/5/2020HC Kerala01 Nov 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

Section 260ASection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE BASANT BALAJI MONDAY, THE 1ST DAY OF NOVEMBER 2021 / 10TH KARTHIKA, 1943 ITA NO. 323 OF 2019 AGAINST THE ORDER IN ITA 67/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH, ERNAKULAM APPELLANT/S: THE PRINCIPAL COMMISSIONER OF INCOME TAX THIRUVANANTHAPURAM BY ADV SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT RESPONDENT/S: M/S. PEROORKADA SERVICE CO-OPERATIVE BANK LTD TC 845/1, PEROORKADA, TRIVANDRUM-695 005. BY ADV SRI.C.A.JOJO THIS INCOME TAX APPEAL HAVING COME UP FOR HEARING ON 01.11.2021, ALONG WITH ITA.142/2019,…

THE PRINCIPAL COMMISSIONER OF INCOME TAX, vs. VILAPPIL SERVICE CO-OPERATIVE BANK LTD.,

Appeals are allowed as indicated above

ITA/142/2019HC Kerala01 Nov 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

Section 260ASection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE BASANT BALAJI MONDAY, THE 1ST DAY OF NOVEMBER 2021 / 10TH KARTHIKA, 1943 ITA NO. 323 OF 2019 AGAINST THE ORDER IN ITA 67/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH, ERNAKULAM APPELLANT/S: THE PRINCIPAL COMMISSIONER OF INCOME TAX THIRUVANANTHAPURAM BY ADV SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT RESPONDENT/S: M/S. PEROORKADA SERVICE CO-OPERATIVE BANK LTD TC 845/1, PEROORKADA, TRIVANDRUM-695 005. BY ADV SRI.C.A.JOJO THIS INCOME TAX APPEAL HAVING COME UP FOR HEARING ON 01.11.2021, ALONG WITH ITA.142/2019,…

THE ITO,WD-2(5), THRISSUR vs. M/S.THIROOR SERVICE CO-OP BANK LTD, THRISSUR

ITA 433/COCH/2019[2015-16]Status: DisposedITAT Cochin04 Sept 2019AY 2015-16

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DRFor Respondent: Sri.M.Ramdas, FCA
Section 80PSection 80P(2)Section 80P(4)

…ral Credit Society cannot be a Bank. A copy of said letter is on record. In the additional grounds of appeal, the Revenue has placed reliance on the judgment of the Hon 'ble Apex Court in the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. CIT reported in 203 ITR 1027(SC). In the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. (supra), the assessee society was effecting sales of agricultural inputs of both members as well as non members. The assessee claimed share of the gross profit out of the transactions with members as a deduction from the combined net profit. On the contrary, in the instant case, the…

THE ITO,WD-2(5), THRISSUR vs. M/S.THIROOR SERVICE CO-OP BANK LTD, THRISSUR

ITA 432/COCH/2019[2014-15]Status: DisposedITAT Cochin04 Sept 2019AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DRFor Respondent: Sri.M.Ramdas, FCA
Section 80PSection 80P(2)Section 80P(4)

…ral Credit Society cannot be a Bank. A copy of said letter is on record. In the additional grounds of appeal, the Revenue has placed reliance on the judgment of the Hon 'ble Apex Court in the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. CIT reported in 203 ITR 1027(SC). In the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. (supra), the assessee society was effecting sales of agricultural inputs of both members as well as non members. The assessee claimed share of the gross profit out of the transactions with members as a deduction from the combined net profit. On the contrary, in the instant case, the…

THE ITO,WD-2(5), THRISSUR vs. M/S.THIROOR SERVICE CO-OP BANK LTD, THRISSUR

ITA 431/COCH/2019[2013-14]Status: DisposedITAT Cochin04 Sept 2019AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DRFor Respondent: Sri.M.Ramdas, FCA
Section 80PSection 80P(2)Section 80P(4)

…ral Credit Society cannot be a Bank. A copy of said letter is on record. In the additional grounds of appeal, the Revenue has placed reliance on the judgment of the Hon 'ble Apex Court in the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. CIT reported in 203 ITR 1027(SC). In the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. (supra), the assessee society was effecting sales of agricultural inputs of both members as well as non members. The assessee claimed share of the gross profit out of the transactions with members as a deduction from the combined net profit. On the contrary, in the instant case, the…

THE ITO, WD-2(5), THRISSUR vs. M/S.THRISSUR SERVICE CO-OP BANK LTD, THRISSUR

ITA 427/COCH/2019[2015-16]Status: DisposedITAT Cochin04 Sept 2019AY 2015-16

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DRFor Respondent: Sri.M.Ramdas, FCA
Section 80PSection 80P(2)Section 80P(4)

…ral Credit Society cannot be a Bank. A copy of said letter is on record. In the additional grounds of appeal, the Revenue has placed reliance on the judgment of the Hon 'ble Apex Court in the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. CIT reported in 203 ITR 1027(SC). In the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. (supra), the assessee society was effecting sales of agricultural inputs of both members as well as non members. The assessee claimed share of the gross profit out of the transactions with members as a deduction from the combined net profit. On the contrary, in the instant case, the…

THE ITO, WD-2(5), THRISSUR vs. M/S.THRISSUR SERVICE CO-OP BANK LTD, THRISSUR

ITA 426/COCH/2019[2014-15]Status: DisposedITAT Cochin04 Sept 2019AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DRFor Respondent: Sri.M.Ramdas, FCA
Section 80PSection 80P(2)Section 80P(4)

…ral Credit Society cannot be a Bank. A copy of said letter is on record. In the additional grounds of appeal, the Revenue has placed reliance on the judgment of the Hon 'ble Apex Court in the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. CIT reported in 203 ITR 1027(SC). In the case of Sabarkantha Zilla Kharid Vechan Sangh Ltd. (supra), the assessee society was effecting sales of agricultural inputs of both members as well as non members. The assessee claimed share of the gross profit out of the transactions with members as a deduction from the combined net profit. On the contrary, in the instant case, the…

THE ITO, WD-5, PALAKKAD vs. M/S.THE AYALUR SERVICE CO-OP BANK LTD, PALAKKAD

ITA 467/COCH/2019[2014-15]Status: FixedITAT Cochin01 Aug 2019AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DR
Section 40Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as “Primary Agricultural Credit Society”. 4. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies / banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, WD-5, PALAKKAD vs. M/S.VADAKKANCHERRY CO-OP SERVICE BANK LTD, PALAKKAD

ITA 470/COCH/2018[2013-14]Status: DisposedITAT Cochin01 Aug 2019AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DR
Section 40Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as “Primary Agricultural Credit Society”. 4. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies / banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, WD-5, PALAKKAD vs. M/S.VADAKKANCHERRY CO-OP SERVICE BANK LTD, PALAKKAD

ITA 469/COCH/2018[2010-11]Status: DisposedITAT Cochin01 Aug 2019AY 2010-11

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DR
Section 40Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as “Primary Agricultural Credit Society”. 4. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies / banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, WD-5, PALAKKAD, PALAKKAD vs. PERINGOTTUKURISSI SERVICE CO-OP BANK LTD, PALAKKAD

ITA 468/COCH/2018[2013-14]Status: DisposedITAT Cochin01 Aug 2019AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DR
Section 40Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as “Primary Agricultural Credit Society”. 4. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies / banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, WD-5, , PALAKKAD vs. M/S.KUTHANNUR SERVICE CO-OP BANK LTD, PALAKKAD

ITA 467/COCH/2018[2013-14]Status: DisposedITAT Cochin01 Aug 2019AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DR
Section 40Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as “Primary Agricultural Credit Society”. 4. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies / banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, WD-5,, PALAKKAD vs. M/S.THE THANNIRANGAD SERVICE CO-OP BANK LTD, PALAKKAD

ITA 200/COCH/2019[2010-11]Status: DisposedITAT Cochin10 Jul 2019AY 2010-11

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Amaljith P.J., CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 40Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as "Primary Agricultural Credit Society." 6. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies I banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, WD-5, PALAKKAD vs. M/S.THEPERUMATTY SERVICE CO-OP BANK LTD, PALAKKAD

ITA 199/COCH/2019[2014-15]Status: DisposedITAT Cochin09 Jul 2019AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.B.Mohan, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as "Primary Agricultural Credit Society." 6. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies I banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, WD-5, PALAKKAD vs. M/S.THEPERUMATTY SERVICE CO-OP BANK LTD, PALAKKAD

ITA 198/COCH/2019[2013-14]Status: DisposedITAT Cochin09 Jul 2019AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.B.Mohan, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 40Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as "Primary Agricultural Credit Society." 6. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies I banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, WD-5, PALAKKAD vs. M/S.THEPERUMATTY SERVICE CO-OP BANK LTD, PALAKKAD

ITA 197/COCH/2019[2011-12]Status: DisposedITAT Cochin09 Jul 2019AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.B.Mohan, CAFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 80PSection 80P(2)Section 80P(4)

…allowed merely on the strength of certificate of registration as "Primary Agricultural Credit Society." 6. The learned CIT (Appeals) ought to have seen that the Hon. Supreme Court in the case of Sabarkhanta Zilla Kharid Vechan Sangh Ltd. Vs. ClT reported in 203 ITR 1027 (SC) had held that eligible deduction under section 80P of the Income tax Act, 1961 in respect of co-operative societies I banks doing both agricultural and non-agricultural activities should not be 100% of the gross profits of such societies etc. but should be limited to the profits generated from agricultural activities alone performed by such…

THE ITO, TRIVANDRUM vs. M/S.PERRORKADA SERVICE CO-OP BANK LTD, TRIVANDRUM

In the result, the appeal of the Revenue in I

ITA 47/COCH/2019[2013-14]Status: DisposedITAT Cochin26 Jun 2019AY 2013-14

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 194A(3)(viia)Section 195Section 263Section 40Section 40A(3)Section 80P

…s per se that it cannot claim the benefit of section 80P(2)(a)(i). (vi) Whether on the facts and in the circumstances of the case, the order of CIT(A) is correct in not duly considering the following case laws (a) Sabargantha Zilla Kharid Vechar Sangh Ltd. (203 ITR 1027) (SC) (b) Perinthalmanna Service Co-operative Bank (363 ITR 68) (Kerala) (c) CIT Vs Kerala State Co-operative Marketing Federation (234 ITR 201) (Ker.) 4. For these and other grounds that may be advanced at the time of hearing the order of the learned Commissioner of Income-tax(Appeals), Trivandrum on the above points may be set aside and tha…

M/S.PEROORKADA SERVICE CO-OP BANK LTD,TRIVANDRUM vs. THE ITO, WD-2(1), TRIVANDRUM, TRIVANDRUM

In the result, the appeal of the Revenue in I

ITA 93/COCH/2018[2014-15]Status: DisposedITAT Cochin26 Jun 2019AY 2014-15

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 143(3)Section 194A(3)(viia)Section 195Section 263Section 40Section 40A(3)Section 80P

…s per se that it cannot claim the benefit of section 80P(2)(a)(i). (vi) Whether on the facts and in the circumstances of the case, the order of CIT(A) is correct in not duly considering the following case laws (a) Sabargantha Zilla Kharid Vechar Sangh Ltd. (203 ITR 1027) (SC) (b) Perinthalmanna Service Co-operative Bank (363 ITR 68) (Kerala) (c) CIT Vs Kerala State Co-operative Marketing Federation (234 ITR 201) (Ker.) 4. For these and other grounds that may be advanced at the time of hearing the order of the learned Commissioner of Income-tax(Appeals), Trivandrum on the above points may be set aside and tha…

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