State Bank Of India v. CIT

ADIM JATI SEWA SAHKARI SAMITI MYDT JOBAT,ALIRAJPUR vs. FACELESS ASSESSMENT OFFICER, ALIRAJPUR

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiadim Jati Sewa Sahkari Samiti National Faceless बनाम/ Mydt., Assessment Centre Vs. 01, Jobat, Jobat, Delhi Alirajpur (Assessee/Appellant) (Revenue/Respondent) Pan: Aaala0577E Assessee By Shri P.D. Nagar, Ar Revenue By Shri Ashish Porwal, Sr. Dr

…integra in view of the decision of this Court in case of Katlary Kariyana Merchant Sahkari Sarafi Mandali Ltd. v Asstt. Commissioner of Income Tax [2022] 140 taxmann.com 602 (Guj.) as well as in case of State Bank of India v Commissioner of Income Tax (2018) 389 ITR 578 (Guj.) wherein it was held that the deduction under section 80P(2)(d) is available to the cooperative societies on the income earned as interest on the investment made with the cooperative bank which in turn, is a cooperative society itself. [Para 28] Reliance placed by the revenue on decisions of the Karnataka High Court in Totgars' Cooperative…

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”

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member), SHRI G D PADMAHSHALI ACCOUNTANT MEMBER I.T.A. No.485/PAN/2025 (A.Y. 2022-23) | Shri Basaveshwar Souharda Sahakari Sangh Niyamit, Kalloli Gokak, Belgavi-591224, Karnataka. | Vs | I.T.O., National e Assessment Centre, Delhi. | PAN .No. AAEAS1697N | | (अपीलार्थी/Appellant) | (प्रत्यर्थी/Respondent) | | Assessee by | None. Letter dated 13.03.2026 | | Revenue by | Sri Sanket Deshmukh.Sr.DR | | सुनवाई की तारीख/Date of Hearing | 16.03.2026 | | घोषणा की ता

…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 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-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

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

…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 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-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

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

…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 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-sectio…

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

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

…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 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-sectio…

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

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

…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 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-sectio…

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

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)

…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 find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that…

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

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)

…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 find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that…

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

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

…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 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-sectio…

SHREE MAHILA CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,BELAGAVI vs. ITO WARD 1 BELAGAVI, BELAGAVI

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.116/Pan/2024 (A.Y. 2017-18) Shree Mahila Credit Souhard Vs Ito-Ward-2, Sahakari Sangh Niyamit, Feroj Khimjibhai Cpx, . Shop.No.3, Maruti Complex, Civil Hospital Road 2 Nd Railway Gate, Tilakwadi, Belagavi-590001. Belgaum-500006, Karnataka. Karnataka. . Pan .No. Aabas9244A (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Pramod Y Vaidya.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.02.2026 घोषणा की तारीख/Date Of Pronouncement 13.02.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of The Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Partially Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Act Made By The Assessing Officer & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act & Sustaining Denial Of Deduction Of Interest On Income Tax Refund Under Section 80P(2)(A)(I) Of The Act.

…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 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment of sub-sectio…

SHREE KESHAV CO OP CREDIT SOCIETY LTD,JUNAGADH vs. THE DCIT/ACIT, CIR 1(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…nsideration as these judgements never distinguished and never overruled by constituting a larger Bench by the Hon’ble Jurisdictional Gujarat High Court. 33. We also find that the Hon’ble jurisdictional High Court in the case of State Bank of India v. CIT 2016 389 ITR 578 (Guj. HC) has also held that any income by way of interest derived by a Co-operative society from its investment with any other Co- operative bank would be deductible u/s. 80P(2)(d) of the Act. 34. We also find that Hon’ble Gujarat High Court has recently modified the judgement delivered by it in Katlary Karayana (supra) on 26th April, 2024 by re…

SHREE KESHAV CO OP CREDIT SOCIETY LTD,JUNAGADH vs. THE DCIT/ACIT, CIR - 1(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…nsideration as these judgements never distinguished and never overruled by constituting a larger Bench by the Hon’ble Jurisdictional Gujarat High Court. 33. We also find that the Hon’ble jurisdictional High Court in the case of State Bank of India v. CIT 2016 389 ITR 578 (Guj. HC) has also held that any income by way of interest derived by a Co-operative society from its investment with any other Co- operative bank would be deductible u/s. 80P(2)(d) of the Act. 34. We also find that Hon’ble Gujarat High Court has recently modified the judgement delivered by it in Katlary Karayana (supra) on 26th April, 2024 by re…