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“Section 2(19)”

Section References (mined)Section 2Section 2(19)744 judgments

The decision most relied on for Section 2(19) is CIT v. Multiplan India Ltd. (38 ITD 320), cited in 2,267 judgments on BharatTax.

Leading authorities on Section 2(19)

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

Pr. CIT v. Totagars
395 ITR 611 · 2017 · High Court
1,074
citing judgments

Interest income earned by a cooperative society from surplus deposits or investments held with a cooperative bank is not eligible for deduction under Section 80P(2)(d) of the Act.

Mavilayi Service Co-operative Bank Ltd. v. CIT
431 ITR 1 · 2021 · Supreme Court
999
citing judgments

Section 80P(4) serves as a proviso to Section 80P(1) and (2), excluding only cooperative banks that are cooperative societies and possess an RBI license for banking business. Its purpose is to exclude cooperative banks operating like commercial banks that lend money to the public.

State Bank Of India v. CIT
389 ITR 578 · 2016 · High Court
817
citing judgments

Income arising from a cooperative society's surplus funds invested in short-term deposits and securities is not attributable to the society's core activities and, therefore, is not eligible for exemption under Section 80P(2)(a)(i) of the Income-tax Act.

Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society
392 ITR 74 · 2017 · High Court
762
citing judgments

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.

Subramanian and Anr. v. Siemens India Ltd. and Anr.
156 ITR 11 · 1985 · High Court
541
citing judgments

When there is a conflict between the decisions of non-jurisdictional High Courts, the view that favors the assessee should be preferred.

Citizen Co-operative Society Ltd. v. ACIT
397 ITR 1 · 2017 · Supreme Court
499
citing judgments

A co-operative credit society engaged in banking business with the general public, accepting deposits from non-members and advancing loans to non-members, is treated as a co-operative bank. Such a society falls under the exclusionary clause of Section 80P(4) and is not eligible for deduction under Section 80P(2)(a)(i).

Judgments citing Section 2(19)

Jai Kondeshwar Nagari Sahakari Badnerapat Sanstha Maryadit, Amravati vs. Income Tax Officer, Ward 3, Amravati

In the result, appeal of the Assessee is allowed in the aforesaid terms

ITA 275/NAG/2025[2022-2023]Status: DisposedITAT Nagpur24 Jun 2025AY 2022-2023

Bench: Shri Narender Kumar Choudhry

For Appellant: NoneFor Respondent: Shri Pankaj Kumar, Ld. Sr.DR
Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

investments, and (ii) such investments should be with any other Co- operative Society. Further, the term „co-operative society• is defined under section 2(19) of the Act as under: "(19) "co-operative society" means a co-operative society registered under the Co-operative Societies Act, 1912 (2

M/S. K274 Uthukuli Paccs Ltd., Tirupur vs. ITO, Ward-1(2), Tirupur

In the result, the appeals filed by the assessee in ITA Nos

ITA 598/CHNY/2025[2018-19]Status: DisposedITAT Chennai24 Jun 2025AY 2018-19

Bench: Shri George George Kand Shri S.R. Raghunatha

For Appellant: Ms. G. Vardini Karthik, AdvocateFor Respondent: Shri Kumar Chandran, JCIT
Section 147Section 250Section 80PSection 80P(2)(d)

operative Bank registered under the Co-operative Societies Act. The Income Tax Act, 1961 has also defined –Co- operative Society- under Section 2(19) as follows: “2(19). “Co-operative society” means a co-operative society registered under the Co~ operative Societies Act, 1912 (2 of 1912), or under

M/S. K274 Uthukuli Paccs Ltd., Tirupur vs. ITO, Ward-1(2), Tirupur

In the result, the appeals filed by the assessee in ITA Nos

ITA 597/CHNY/2025[2017-18]Status: DisposedITAT Chennai24 Jun 2025AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunatha

For Appellant: Ms. G. Vardini Karthik, AdvocateFor Respondent: Shri Kumar Chandran, JCIT
Section 147Section 250Section 80PSection 80P(2)(d)

operative Bank registered under the Co-operative Societies Act. The Income Tax Act, 1961 has also defined –Co- operative Society- under Section 2(19) as follows: “2(19). “Co-operative society” means a co-operative society registered under the Co~ operative Societies Act, 1912 (2 of 1912), or under

K274 Uthukuli Paccs Ltd., Tirupur vs. ITO, Ward-1(2), Tirupur

In the result, the appeals filed by the assessee in ITA Nos

ITA 596/CHNY/2025[2015-16]Status: DisposedITAT Chennai24 Jun 2025AY 2015-16

Bench: Shri George George Kand Shri S.R. Raghunatha

For Appellant: Ms. G. Vardini Karthik, AdvocateFor Respondent: Shri Kumar Chandran, JCIT
Section 147Section 250Section 80PSection 80P(2)(d)

operative Bank registered under the Co-operative Societies Act. The Income Tax Act, 1961 has also defined –Co- operative Society- under Section 2(19) as follows: “2(19). “Co-operative society” means a co-operative society registered under the Co~ operative Societies Act, 1912 (2 of 1912), or under

The DCIT, Cir-3(2) Gangtok, Gangtok Sikkim vs. Sikkim State Cooperative Supply and Marketing Federation Limited, Gangtok Sikkim

ITA 1583/KOL/2024[2020-21]Status: DisposedITAT Kolkata18 Jun 2025AY 2020-21

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 250Section 80P

operative societies’ registered under the State laws for registration of co-operative societies; hence a “co- operative society” within the meaning of section 2 (19) of the Act, The jurisdictional Assessing Officer (JAO) is directed to allow the claim of deduction under section 80P(2)(d) and re-compute total ... Vide submission dated 09/11/2015, the assessee had submitted as below: “The term co- operative society has been defined in the Act in section 2(19) which read as : Co-operative society means a society registered under the Co-operative Societies Act, 1912 or under any other law for the time

Deputy Commissioner of Income Tax, Cir-3(2), Gangtok, Gangtok Sikkim vs. Sikkim State Cooperative Supply and Marketing Federation Limited, Gangtok Sikkim

ITA 1582/KOL/2024[2018-19]Status: DisposedITAT Kolkata18 Jun 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 250Section 80P

operative societies’ registered under the State laws for registration of co-operative societies; hence a “co- operative society” within the meaning of section 2 (19) of the Act, The jurisdictional Assessing Officer (JAO) is directed to allow the claim of deduction under section 80P(2)(d) and re-compute total ... Vide submission dated 09/11/2015, the assessee had submitted as below: “The term co- operative society has been defined in the Act in section 2(19) which read as : Co-operative society means a society registered under the Co-operative Societies Act, 1912 or under any other law for the time

Bhatadi Opencast Karmachari Sahakari Patsanstha Maryadit, Bhatadi, Chandrapur vs. ITO Ward-1, Chandrapur

In the result, appeal of the assessee is allowed

ITA 89/NAG/2025[2018-19]Status: DisposedITAT Nagpur17 Jun 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry

For Appellant: Ms. Veena Agrawal, CAFor Respondent: Shri Anand Nagrale, Sr.DR
Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(d)

investments, and (ii) such investments should be with any other Co- operative Society. Further, the term „co-operative society• is defined under section 2(19) of the Act as under: "(19) "co-operative society" means a co-operative society registered under the Co-operative Societies Act, 1912 (2

ACIT, Circle-4, Nagpur vs. The Vidarbha Co Operative Marketing Federation Ltd, Nagpur

In the result, appeal of the Revenue stands dismissed

ITA 196/NAG/2025[2020-21]Status: DisposedITAT Nagpur16 Jun 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry& Shri K.M. Roy

For Appellant: Shri Manoj Moriyani, AdvocateFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

investments, and (ii) such investments should be with any other Co- operative Society. Further, the term „co-operative society• is defined under section 2(19) of the Act as under: "(19) "co-operative society" means a co-operative society registered under the Co-operative Societies Act, 1912 (2

Jagruti Co Op Hsg Soc Ltd, Mumbai vs. ITO Ward (197)(6), Mumbai

In the result, the appeal by the Assessee stands allowed

ITA 372/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Jun 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryassessment Year: 2014-15 M/S. Jagruti Co Op Hsg Soc Ito Ward –(197)(6) Ltd. Cpc Bangaluru, L.J. Road Mahim, Vs. 560500. Mumbai-400016. Pan: Aaaat9842L (Appellant) (Respondent) Present For: Assessee By : Shri Pratik Jain, Ld. A.R. Revenue By : Shri Kavan Limbasiya, Ld. D.R. Date Of Hearing : 12.06.2025 Date Of Pronouncement : 12.06.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 19.11.2024, Impugned Herein, Passed By The Addl/Jcit (A) (In Short Ld. Addl/Joint Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2014-15. 2. In This Case, The Intimation/Order U/S. 143(1) Of The Act Was Issued On Dated 20.05.2015 By The Ito Ward-(197) (6) Mumbai, Whereby The Deduction Claimed By The Assessee U/S. 80(2)(D) Of The Act Amounting To Rs. 7,36,459/- Earned On Its Investment & Saving Bank Account Maintained With Saraswat Co-Operative Bank & The Nkgsb Co-Operative Bank Was Disallowed. The Assessee Against The Said Intimation Dated 20.05.2015 Filed A Rectification Application U/S. 154 Of The Act, However, No Order For Rectification Has Ever Been Passed By The Cpc. The Assessee On Realizing Its 2 M/S. Jagruti Co Op Hsg Soc Ltd. Mistake Challenged The Said Intimation U/S. 143(1) Dated 25.05.2025 By Filing First Appeal On Dated 12.06.2024 But With The Delay Of More Than 9 Years. The Ld. Addl/Joint Commissioner By Considering The Peculiar Facts & Circumstances Of The Case, Ultimately Declined To Entertain The Request For Condonation Of Delay & Dismissed The Appeal Of The Assessee In Limine Without Making Any Discussion On Merit Or On Any Other Aspect.

For Appellant: Shri Pratik Jain, Ld. A.RFor Respondent: Shri Kavan Limbasiya, Ld. D.R
Section 14Section 143(1)Section 154Section 250Section 80(2)(d)Section 80P(2)(d)

investments, and (ii) such investments should be with any other Co-operative Society. Further, the term co-operative society" is defined under section 2(19) of the Act as under: "(19) "co-operative society" means a co-operative society registered under the Co-operative Societies Act, 1912 (2

Sagar Tech Plaza A Premises Co-Op Society Ltd, Mumbai vs. Income Tax Department, Bandra Mumbai

In the result, the Assessee’s appeals are allowed

ITA 2687/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Narender Kumar Choudhryassessment Year: 2019-20 & Assessment Year: 2022-23

For Appellant: Shri Virat Doshi, Ld.ARFor Respondent: Shri Kavan Limbasiya, Ld. Sr.D.R
Section 2(19)Section 250Section 80(2)(d)Section 80PSection 80P(1)Section 80P(2)(a)Section 80P(2)(d)

interest or dividend is earned by the Co-operative Society from the Society. Further, the term "co-operative society" is defined under section 2(19) of the Act as under: "(19) "co-operative society" means a co- operative society registered under the Co- operative Societies Act, 1912 (2

Sagar Tech Plaza A Premises Co Op Society Ltd, Mumbai vs. Income Tax Department, Bandra Mumbai

In the result, the Assessee’s appeals are allowed

ITA 2686/MUM/2025[2019-20]Status: DisposedITAT Mumbai11 Jun 2025AY 2019-20

Bench: Shri Narender Kumar Choudhryassessment Year: 2019-20 & Assessment Year: 2022-23

For Appellant: Shri Virat Doshi, Ld.ARFor Respondent: Shri Kavan Limbasiya, Ld. Sr.D.R
Section 2(19)Section 250Section 80(2)(d)Section 80PSection 80P(1)Section 80P(2)(a)Section 80P(2)(d)

interest or dividend is earned by the Co-operative Society from the Society. Further, the term "co-operative society" is defined under section 2(19) of the Act as under: "(19) "co-operative society" means a co- operative society registered under the Co- operative Societies Act, 1912 (2

Rajmala Premises Co-Operative Society Ltd, Mumbai vs. ITO Ward 19(3)(1), Mumbai

In the result appeal filed by the assessee stands allowed

ITA 2706/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Jun 2025AY 2018-19

Bench: Shri Narender Kumar Choudhryassessment Year: 2018-19

For Appellant: Shri Aditya Ramchandran, Ld. ARFor Respondent: Shri Kavan Limbasiya,Ld. Sr.D.R
Section 154Section 234ASection 250Section 80PSection 80P(2)(d)

investments, and (ii) such investments should be with any other Co-operative Society. Further, the term "co operative society? is defined under section 2(19) of the Act as under: "(19) "co-operative society means a co-operative society registered under the Co-operative Societies Act, 1912 (2

Laxmi Industrial Premises Co-Op Society Ltd, Mumbai vs. ITO Ward 22(2)(1), Mumbai

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

ITA 2692/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Jun 2025AY 2020-21

Bench: Shri Narender Kumar Choudhryassessment Year: 2020-21

For Appellant: Shri Ajay Wadake, Ld. A.RFor Respondent: Shri P D Chougule, Ld. Sr. D.R
Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(d)

investments, and (ii) such investments should be with any other Co-operative Society. Further, the term „co-operative society‟ is defined under section 2(19) of the Act as under: “(19) "co-operative society" means a co-operative society registered under the Co-operative Societies Act, 1912 (2

Shri Anantanath Alpasankhyatar Vividh Uddeshagal Souhard Sahakari Sangh Niy, Belagavi vs. Income Tax Officer, NFAC, Delhi

ITA 6/PAN/2025[2009-10]Status: DisposedITAT Panaji03 Jun 2025AY 2009-10

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 006/Pan/2025 Assessment Year : 2009-10 Shri Anantanath Alpasankhyatar Vivid Uddheshagal Souhardha Sahakari Sangh Niyamit [‘Saavusssn’] 1738, Anantnath Building, Jain Galli, Main Rd., Kannur Niyamit Kalloli, Kalloli, Belagavi. Pan : Aagts1962B . . . . . . . Appellant V/S Income Tax Office, Ward-1, Gokak, Belagavi. . . . . . . . Respondent Appearances Assessee By : Mr Sachin Nichal [‘Ld. Ar’] Revenue By : Mr Deshmukh Prakash [‘Ld. Dr’] Date Of Conclusive Hearing : 02/06/2025 Date Of Pronouncement : 03/06/2025 Order Per G. D. Padmahshali; This Appeal Is Filed Against Din & Order 1070608483(1) Dt. 25/11/2024 Passed By The National Faceless Appeal Centre, Delhi [‘Ld. Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Arisen Out Of Order Of Penalty Dt. 23/03/2022 Passed U/S 271(1)(C) Of The Act By The National Faceless Assessment Centre Delhi [‘Ld. Nfeac’ Hereinafter] Anent To Assessment Year 2009-10 [‘Ay’ Hereinafter].

For Appellant: Mr Sachin Nichal [‘Ld. AR’]For Respondent: Mr Deshmukh Prakash [‘Ld. DR’]
Section 143(3)Section 250Section 271(1)(c)Section 80PSection 80P(4)

assessment proceedings the appellant furnished certain key information to the Revenue that; (i) it is a co- operative society within the meaning of section 2(19) of ITAT-Panaji Page 6 of 10 SAAVUSSSN Vs ITO, Gokak ITA Nos.006/PAN/2025 AY: 2009-10 the Act, and (ii) was in receipt ... 2) deduction in limine was exclusively founded on the basis of rejection of appellant’s status as ‘co-operative society’ in view of section 2(19) r.w.s. 2(31) of the Act. 7. We thus note that, the claim of the appellant made in the return of income

Vijay Sahakari Pat Sanstha Limited, Ichalkaranji vs. ITO Ward-2, Ichalkaranji

In the result, the appeal of the assessee is allowed

ITA 90/PUN/2025[2017-18]Status: DisposedITAT Pune30 May 2025AY 2017-18

Bench: Shri Manish Borad & Ms. Astha Chandra

For Appellant: Smt. Deepa KhareFor Respondent: Shri Akhilesh Srivastava
Section 143(1)Section 143(2)Section 56Section 80PSection 80P(2)(a)

आयकर अपीलीय अधिकरण “एक सदस्य मामला” न्यायपीठ पुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, PUNE BEFORE SHRI

Deputy Commissioner of Income Tax (Exemption)-2(1), Mumbai vs. Mumbai Metropolitan Region Development Authority, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3936/MUM/2023[2018-19]Status: DisposedITAT Mumbai28 May 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

Section 11Section 12ASection 143(3)Section 154Section 2(15)

section 44 of the MMRDA Act, whereby any arears receivable by MMRDA can be recovered as “arears of land revenue”. As defined under section 2(19) of The Maharashtra Land Revenue Code, 1966, the term ‘land revenue’ has been defined as under. “(19) “ land revenue” means all sums and payments

Deputy Commissioner of Income-Tax(Exemption)-2(1), Mumbai vs. Mumbai Metropolitan Region Development Authority, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3795/MUM/2023[2016-17]Status: DisposedITAT Mumbai28 May 2025AY 2016-17

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Shri Saurabh Soparkar, Sr. AdvocateFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. DR
Section 11Section 12ASection 143(3)Section 154Section 2(15)

section 44 of the MMRDA Act, whereby any arears receivable by MMRDA can be recovered as “arears of land revenue”. As defined under section 2(19) of The Maharashtra Land Revenue Code, 1966, the term ‘land revenue’ has been defined as under. “(19) “ land revenue” means all sums and payments

Deputy Commissioner of Income-Tax(Exemption)-2(1), Mumbai vs. Mumbai Metropolitan Region Development Authority, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3794/MUM/2023[2017-18]Status: DisposedITAT Mumbai28 May 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Shri Saurabh Soparkar, Sr. AdvocateFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. DR
Section 11Section 12ASection 143(3)Section 154Section 2(15)

section 44 of the MMRDA Act, whereby any arears receivable by MMRDA can be recovered as “arears of land revenue”. As defined under section 2(19) of The Maharashtra Land Revenue Code, 1966, the term ‘land revenue’ has been defined as under. “(19) “ land revenue” means all sums and payments

Deputy Commissioner of Income-Tax(Exemption)-2(1), Mumbai vs. Mumbai Metropolitan Region Development Authority, Mumbai

ITA 3791/MUM/2023[2018 19]Status: DisposedITAT Mumbai28 May 2025

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

Section 11Section 126Section 12ASection 143(3)Section 154Section 2(15)Section 3

section 44 of the MMRDA Act, whereby any arears receivable by MMRDA can be recovered as “arears of land revenue”. As defined under section 2(19) of The Maharashtra Land Revenue Code, 1966, the term ‘land revenue' has been defined as under. “(19) “ land revenue” means all sums and payments

Parsi Salsette Bldg No. 1 Chs Limited, Mumbai vs. Income Tax Officer 24(3)(1), Mumbai

Accordingly, Ground No. II raised by the Assessee is allowed and as a result, Ground No

ITA 1734/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 May 2025AY 2021-22

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Haridas BhatFor Respondent: Shri Akhtar Hussain Ansari
Section 143(1)Section 143(3)Section 80Section 80PSection 80P(2)(d)Section 80P(4)

Secondly, for purposes of eligibility for deduction, the assessee must be a "co-operative society". A co- operative society is defined in Section 2(19) of the IT Act, as being a co-operative society registered either under the Co- operative Societies Act, 1912 or under any other