Totgars Co-operative Sale Society Ltd. v. ITO

322 ITR 283Supreme Court of India2010#32 most cited

What is Totgars Co-operative Sale Society Ltd. v. ITO authority for?

The interest income earned by a cooperative society from investing its surplus funds in fixed deposits with banks is not "derived from" its eligible business activities and is taxable as "income from other sources" under Section 56, thus not qualifying for deduction under Section 80P.

1,283

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2014 to 2026.

Also referred to as

Totgars Co-operative Sale Society · 322 ITR 283 · Section 80P · Section 80P(2)(d) · Section 80P(2)(a)(i) · interest income cooperative society · fixed deposit interest deduction · income from other sources Section 56 · derived from business · surplus funds investment

Also reported as

188 Taxmann.com 282

Sections most often in play

Section 80P(2)(d)Section 80P(2)(a)(i)Section 143(3)Section 80PSection 80P(4)Section 250Section 56Section 263

Issues it is cited on

section 80(2)(d)section 80p(2)(a)(iii)section 80p(4)section 2(19)section 80p(1)section 80p(2)(c)section 80(p)(2)(d)section 5(b)section 80p(2)(d)section 80p(2)(a)section 194a(3)(v)section 80p(2)(a)(i)

Judgments citing Totgars Co-operative Sale Society Ltd. v. ITO

KAI FAKIRA JAIRAM PATIL SAHAKARI PATSANSTHA MARYADIT SHAHADA,NANDURBAR vs. ITO, WARD-1, DHULE, DHULE

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

ITA 3110/PUN/2025[2016-17]Status: DisposedITAT Pune17 Apr 2026AY 2016-17
For Appellant: Shri Manoj Parmar
Section 139(1)Section 147Section 148Section 148ASection 80PSection 80P(2)(a)Section 80P(2)(d)

…s court in CIT v. Andhra Pradesh State Cooperative Bank Ltd. [2011] 12 taxmann.com 66/200 Taxman 200/336 ITR 516, the Revenue places strong reliance upon the decision of the Supreme Court in Totgar's Co-operative Sale Society Ltd. v. ITO [2010] 188 Taxman 282/322 ITR 283. …………………… 34. The case before the Supreme Court in Totgar's Co- operative Sale Society Ltd.'s case (supra) was in respect of a co-operative credit society, which was also marketing the agricultural produce of its members. As seen from the facts disclosed in the decision of the Karnataka High Court in Totgars, from out of which the decision of the…

THE KARNATAKA STATE COOPERATIVE AGRICULTURE AND DEVELOPMENT BANK LIMITED ,BANGLAORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 1821/BANG/2025[2022-23]Status: DisposedITAT Bangalore09 Apr 2026AY 2022-23

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2022-23

For Appellant: Shri Bhardwaj Sheshadri, Advocate &For Respondent: Shri Subramanian, JCIT (DR)
Section 250Section 56Section 80PSection 80P(2)(a)

…ilities to members does not fall within the ambit of section 80P(2)(a)(i) of the Act and is not eligible for deduction. The AO further relied on the judgment of the Hon’ble Supreme Court in the case of Totgars Co-operative Sale Society Ltd. v. ITO reported in 322 ITR 283 and held that only operational income attributable to the specified activities mentioned in section 80P(2)(a) is eligible for deduction, and interest income earned on surplus funds not immediately required for business purposes is taxable as “Income from other sources” under section 56 of the Act. Accordingly, the AO held that interest on investm…

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

ITA 663/IND/2025[2020-21]Status: DisposedITAT Indore27 Mar 2026AY 2020-21

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

Section 143(3)Section 253(5)Section 80P(2)(d)Section 80P(4)

…ed by a “co-operative society” from a “co-operative bank” is not eligible for deduction u/s 80P(2)(d). In coming to such a conclusion, the AO has precisely relied upon decision of Hon’ble Supreme Court in Totagars Co-operative Sale Society Ltd. Vs. ITO (2010) 322 ITR 283 (SC) / (2010) 188 Taxman 282 (SC). 6. Before us, the Ld. AR for assessee/appellant has cited decisions of different High Courts and ITAT Benches holding in favour of assessee. The decisions relied by Ld. AR are as follows: (i) Hon’ble Gujrat High Court – PCIT Vs. Ashwinkumar Arban Co-operative Society Ltd. (2024) 168 taxmann.com 314 (Gujrat) (ii)…

DEOBAND COOPERATIVE CANE DEVELOPMENT UNION LTD,DEOPAND SAHARANPUR vs. ASSESSING OFFICER, NFAC DELHI (ASSESSMENT UNIT)

Appeal is allowed in above terms

ITA 6638/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumara.Yr. : 2022-23 Deoband Cooperative Vs. Ao, Nfac, Delhi Cane Development Union (Assessment Unit) Ltd., Office Of Cooperative Cane Development Deoband, Uttar Pradesh-247554 (Pan: Aaaad0519J)

For Appellant: Sh. J.N. Shukla, AdvFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 80Section 80PSection 80P(2)Section 80P(2)(a)

…declined the assessee’s section 80P deduction claim on interest received on investment in form of FDR’s. 4. Ld. Sr. DR. relied upon the orders of the authorities below and also placed the reliance on the case of Totgars Co-operative Sale Society Ltd. Vs. ITO 322 ITR 283 (SC) that such an interest income could not be held to have been derived from the eligible business u/s 80P(2) of the Act. 5. We find no merit in the Revenue’s instant vehement arguments in light of (2024) 164 taxmann.com 382 (Pune Tribu.) ITO Vs. Shri Bhairavnath Multistate Cooperative Credit Society Ltd. rejecting the very stand as under: “5.…

AUTO NIRVAHAKARA CREDIT OPERATIVE SOCIETY LIMITED,UDUPI vs. INCOME TAX OFFICER, WARD-3, UDUPI

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

ITA 2214/BANG/2025[2017-18]Status: DisposedITAT Bangalore17 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Prasanna Shenoy, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 250Section 28Section 80P(2)(a)

…2. The relevant facts are that the assessee earned an interest income of Rs. 32,043 from scheduled banks. The AO relying on the judicial of Totgars, Co-operative Sale Society Ltd. vs. Income-tax Officer, Karnataka reported in [2010] 188 Taxman 282 (SC)/[2010] 322 ITR 283 (SC)/[2010] 229 CTR 209 (SC)[08-02-2010] submitted that interest earned from deposits from scheduled banks does not qualify for deduction u/s 80P of the Act and consequently, taxed the same as income from other sources. 13. Aggrieved, assessee preferred an appeal before the Ld. CIT(A) who rejected the plea of assessee and upheld the disallowance…

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

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

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

…at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale Society Ltd. vs. ITO (2010) 322 ITR 283 (SC) is concerned, we are of the considered view that the being distinguishable on facts had wrongly been relied upon by him. The adjudication by the Hon"ble Apex Court in the aforesaid case was in context of Sec. 80P(2)(a)(i), and not on the entitlement of a cooperative society towards deduction under Sec. 80P(2) (d) on the interest income on th…

PERURCHETTIPALAYAM PACCS,COIMBATORE vs. ITO, NCW-4(2), COIMBATORE

In the result, appeals filed by the assessee are allowed

ITA 3223/CHNY/2025[2020-21]Status: DisposedITAT Chennai13 Mar 2026AY 2020-21

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Mr.S. Bhupendran, AdvocateFor Respondent: Mr.N. Madan Kumar, JCIT
Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of the Act by relying on the ITA Nos.3220 to 3222 & 3223/Chny/2025 (AYs 2016-17 to 2018-19 & 2020-21) Perurchettipalayam PACCS :: 3 :: decision of the Hon’ble Supreme Court in the case of Totgars Co-op. Sale Society Ltd. v. ITO, Karnataka reported in [2010] 322 ITR 283 (SC) and the AO disallowed the claim of deduction u/s.80P of the Act and separately assessed the same u/s.56 of the Act i.e. “income from other sources”. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who confirmed the view of the AO that the deduction is neither allowable u/s.80P(2)(a)(i) of the Act nor u/s.80P(2)(d) of the A…

PERURCHETTIPALAYAM PACCS,COIMBATORE vs. ITO, NCW-4(2), COIMBATORE

In the result, appeals filed by the assessee are allowed

ITA 3222/CHNY/2025[2018-19]Status: DisposedITAT Chennai13 Mar 2026AY 2018-19

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Mr.S. Bhupendran, AdvocateFor Respondent: Mr.N. Madan Kumar, JCIT
Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of the Act by relying on the ITA Nos.3220 to 3222 & 3223/Chny/2025 (AYs 2016-17 to 2018-19 & 2020-21) Perurchettipalayam PACCS :: 3 :: decision of the Hon’ble Supreme Court in the case of Totgars Co-op. Sale Society Ltd. v. ITO, Karnataka reported in [2010] 322 ITR 283 (SC) and the AO disallowed the claim of deduction u/s.80P of the Act and separately assessed the same u/s.56 of the Act i.e. “income from other sources”. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who confirmed the view of the AO that the deduction is neither allowable u/s.80P(2)(a)(i) of the Act nor u/s.80P(2)(d) of the A…

PERURCHETTIPALAYAM PACCS,COIMBATORE vs. ITO, NCW-4(2), COIMBATORE

In the result, appeals filed by the assessee are allowed

ITA 3221/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Mr.S. Bhupendran, AdvocateFor Respondent: Mr.N. Madan Kumar, JCIT
Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of the Act by relying on the ITA Nos.3220 to 3222 & 3223/Chny/2025 (AYs 2016-17 to 2018-19 & 2020-21) Perurchettipalayam PACCS :: 3 :: decision of the Hon’ble Supreme Court in the case of Totgars Co-op. Sale Society Ltd. v. ITO, Karnataka reported in [2010] 322 ITR 283 (SC) and the AO disallowed the claim of deduction u/s.80P of the Act and separately assessed the same u/s.56 of the Act i.e. “income from other sources”. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who confirmed the view of the AO that the deduction is neither allowable u/s.80P(2)(a)(i) of the Act nor u/s.80P(2)(d) of the A…

PERURCHETTIPALAYAM PACCS,COIMBATORE vs. ITO, NCW-4(2), COIMBATORE

In the result, appeals filed by the assessee are allowed

ITA 3220/CHNY/2025[2016-17]Status: DisposedITAT Chennai13 Mar 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Mr.S. Bhupendran, AdvocateFor Respondent: Mr.N. Madan Kumar, JCIT
Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of the Act by relying on the ITA Nos.3220 to 3222 & 3223/Chny/2025 (AYs 2016-17 to 2018-19 & 2020-21) Perurchettipalayam PACCS :: 3 :: decision of the Hon’ble Supreme Court in the case of Totgars Co-op. Sale Society Ltd. v. ITO, Karnataka reported in [2010] 322 ITR 283 (SC) and the AO disallowed the claim of deduction u/s.80P of the Act and separately assessed the same u/s.56 of the Act i.e. “income from other sources”. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who confirmed the view of the AO that the deduction is neither allowable u/s.80P(2)(a)(i) of the Act nor u/s.80P(2)(d) of the A…

SHRI DURDUNDESHWAR URBAN CREDIT SOUHARD SAHAKARI NYT,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, GOKAK

Appeals are allowed for statistical purposes

ITA 311/PAN/2025[2017-18]Status: DisposedITAT Panaji12 Mar 2026AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita No. 306 To 307 & 311/Pan/2025 Assessment Year : 2017-18 & 2020-21 Shri Durdundeshwar Urban Credit Souhard Sahakari Niyamita Subhash Road, Sankeshwar Belagavi-591313 Pan:Aaaas5612D . . . . . . . Appellant

For Appellant: NoneFor Respondent: Ms Rijula Uniyal [‘Ld. DR’]
Section 143(3)Section 246ASection 250Section 270ASection 80PSection 80P(2)

…rs above 15% of regular members of the society. In addition to above denial of 80(2) deduction, by placing reliance on catena of judicial precedents including the judgement of Hon’ble Apex Court in the case of ‘Totgar’s Co-op. Sale Society Ltd. Vs ITO’ [2010, 322 ITR 283 (SC)] the Ld. AO treated the total interest received by the assessee from its investment held with co-operative banks as income of the assessee under the head income from other sources. ITA No. 307/PAN/2025 AY 2020-21 6. Similarly for the year under consideration the assessee’s return filed on 08/12/2020 declaring an income of ₹Nil after claimin…

SHRI DURDUNDESHWAR URBAN CREDIT SOUHARD SAHAKARI NYT,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, GOKAK

Appeals are allowed for statistical purposes

ITA 307/PAN/2025[2020-21]Status: DisposedITAT Panaji12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita No. 306 To 307 & 311/Pan/2025 Assessment Year : 2017-18 & 2020-21 Shri Durdundeshwar Urban Credit Souhard Sahakari Niyamita Subhash Road, Sankeshwar Belagavi-591313 Pan:Aaaas5612D . . . . . . . Appellant

For Appellant: NoneFor Respondent: Ms Rijula Uniyal [‘Ld. DR’]
Section 143(3)Section 246ASection 250Section 270ASection 80PSection 80P(2)

…rs above 15% of regular members of the society. In addition to above denial of 80(2) deduction, by placing reliance on catena of judicial precedents including the judgement of Hon’ble Apex Court in the case of ‘Totgar’s Co-op. Sale Society Ltd. Vs ITO’ [2010, 322 ITR 283 (SC)] the Ld. AO treated the total interest received by the assessee from its investment held with co-operative banks as income of the assessee under the head income from other sources. ITA No. 307/PAN/2025 AY 2020-21 6. Similarly for the year under consideration the assessee’s return filed on 08/12/2020 declaring an income of ₹Nil after claimin…

SHRI DURDUNDESHWAR URBAN CREDIT SOUHARD SAHAKARI NYT,BELAGAVI vs. INCOME TAX OFFICER, WARD -1, GOKAK

Appeals are allowed for statistical purposes

ITA 306/PAN/2025[2020-21]Status: DisposedITAT Panaji12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita No. 306 To 307 & 311/Pan/2025 Assessment Year : 2017-18 & 2020-21 Shri Durdundeshwar Urban Credit Souhard Sahakari Niyamita Subhash Road, Sankeshwar Belagavi-591313 Pan:Aaaas5612D . . . . . . . Appellant

For Appellant: NoneFor Respondent: Ms Rijula Uniyal [‘Ld. DR’]
Section 143(3)Section 246ASection 250Section 270ASection 80PSection 80P(2)

…rs above 15% of regular members of the society. In addition to above denial of 80(2) deduction, by placing reliance on catena of judicial precedents including the judgement of Hon’ble Apex Court in the case of ‘Totgar’s Co-op. Sale Society Ltd. Vs ITO’ [2010, 322 ITR 283 (SC)] the Ld. AO treated the total interest received by the assessee from its investment held with co-operative banks as income of the assessee under the head income from other sources. ITA No. 307/PAN/2025 AY 2020-21 6. Similarly for the year under consideration the assessee’s return filed on 08/12/2020 declaring an income of ₹Nil after claimin…

UDAYA SOUHARDA CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-5(1)(1), BANGALORE

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

ITA 2472/BANG/2025[2020-21]Status: DisposedITAT Bangalore12 Mar 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Tharun Kothari, CAFor Respondent: Shri Subramanian, JCIT (DR)
Section 57Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…to providing credit facility to the members. In holding so, the AO placed reliance on the decision of Hon’ble Supreme court in the Totgars, Co-Operative Sales Society Ltd Vs. ITO in Civil Appeal Nos. 1622 to 1629 of 2010, dated 8th February 2010, reported in 322 ITR 283/ 188 Taxman 282. Furthermore, the AO was of the view that earning income by way of deposits and investment with cooperative bank is not eligible for deduction under . Page 3 of 22 section 80P(2)(d) of the Act as cooperative bank is not a cooperative society for the purpose of section 80P of the Act. Hence, the AO disallowed the claim of the asse…

SHRI. SHANTHISAGAR CO OP CREDIT SOCIETY LIMITED,HUBLI vs. INCOME TAX OFFICER, WARD-2(1), HUBLI

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

ITA 2081/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ana High . ITA No.2081 /Bang/2025 Page 3 of 32 Court decision in case of CIT vs. Punjab State Co-op Agricultural Development Bank Ltd reported in 389 ITR 607 and ruling of Hon’ble Supreme Court in the case of Totagars Cooperative Sales Society reported in 322 ITR 283. 6.1 The AO also considered reliance placed by the assessee on the decision of Hon’ble Karnataka high court in the case of Tumkur Merchant Souharda Credit Cooperative Ltd reported in 230 taxman 309. The AO found the ratio of Hon’ble High Court in the case of Tumkur Merchant Souharda was in the context where assessee derived income from business o…

SREE CAUVERY SOUHARDA CREDIT SAHAKARI SANGHA NIYAMITHA,BENGALURU vs. INCOME TAX OFFICER WARD 1(1)(1), BENGALURU

ITA 1854/BANG/2025[2018-19]Status: DisposedITAT Bangalore12 Mar 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Smt. Sumana, CAFor Respondent: Shri Subramanian, JCIT (DR
Section 10Section 250Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K, JUDICIAL MEMBER ITA No.1854 & 1855/Bang/2025 Assessment Year: 2018-19 Sree Cauvery Souharda Credit Sahakari Vs. The Income Tax Officer, Sangha Niyamitha, Ward – 1(1)(1), No.7, Kodava Samaja Building, Bangalore. 1st Main Road, Vasanthnagar, Bangalore – 560 002. PAN – AAAJS 2172 F APPELLANT RESPONDENT Assessee by : Smt. Sumana, CA Revenue by : Shri Subramanian, JCIT (DR Date of hearing : 02.03.2026 Date of Pronouncement : 12.03.2026 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: The…

SRI GURU RAMALINGESHWARA SOUHARDA PATTINA SAHAKARI NIYAMITHA ,MASKI vs. PR. COMMISSIONER OF INCOME TAX , HUBLI

In the result, the appeal of the assessee is hereby allowed

ITA 1174/BANG/2025[2020-21]Status: DisposedITAT Bangalore12 Mar 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2020-21

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Muthu Shankar, JCIT (DR)
Section 143(3)Section 263Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K, JUDICIAL MEMBER Assessment Year: 2020-21 Sri Guru Ramalingeshwara Souharda Vs. The Pr. Commissioner of Pattina Sahakari Niyamitha, Income Tax, 1, Ashwini Complex, Hubli. Gesh, Maski – 584 124. PAN – AAVAS 1264 J APPELLANT RESPONDENT Assessee by : Shri Ravishankar, Advocate Revenue by : Shri Muthu Shankar, JCIT (DR) Date of hearing : 04.03.2026 Date of Pronouncement : 12.03.2026 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: The present appeal, filed by the assessee, is against the…

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)

…at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale Society Ltd. vs. ITO (2010) 322 ITR 283 (SC) is concerned, we are of the considered view that the 9 ITA. No..55/PAN/2026 The Camp Multipurpose Primary Agriculture Cooperative Society Limited being distinguishable on facts had wrongly been relied upon by him. The adjudication by the Hon"ble Apex Court in the aforesaid case was in context of Sec. 80P(2)(a)(i), and not on the entitlemen…

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)

…at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale Society Ltd. vs. ITO (2010) 322 ITR 283 (SC) is concerned, we are of the considered view that the being distinguishable on facts had wrongly been relied upon by him. The adjudication by the Hon"ble Apex Court in the aforesaid case was in context of Sec. 80P(2)(a)(i), and not on the entitlement of a cooperative society towards deduction under Sec. 80P(2) (d) on the interest income on th…

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)

…at par with other banks would no more be entitled for claim of deduction under Sec. 80P(4) of the Act. Insofar the reliance placed by the Pr. CIT on the judgment of the Hon'ble Supreme Court in the case of Totgars Co-operative Sale Society Ltd. vs. ITO (2010) 322 ITR 283 (SC) is concerned, we are of the considered view that the being distinguishable on facts had wrongly been relied upon by him. The adjudication by the Hon"ble Apex Court in the aforesaid case was in context of Sec. 80P(2)(a)(i), and not on the entitlement of a cooperative society towards deduction under Sec. 80P(2) (d) on the interest income on th…

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