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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)

Shivagiri Co-Op Credit Society Ltd, Belagavi vs. Income Tax Officer, Ward - 1(3), Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 138/PAN/2024[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

operative engaged in the business of providing credit facilities to its members. The definition of "co-operative society is provided in section 2(19) of the Act. As per the provisions of section 2(19), "co-operative society" means a co-operative society registered under the Co-operative societies ... state for the registration of the cooperative society. When the provisions of Page 30 of 36 Akshaya Co-Op credit society Limited & others. section 2(19) of the Act were applied to the appellant society, it was observed that the appellant society was registered u/s. 8 (section

Shree Mahila Credit Souhard Sahakari Sangh Niyamit, Belagavi vs. ITO Ward 1 Belagavi, Belagavi

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 117/PAN/2024[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

operative engaged in the business of providing credit facilities to its members. The definition of "co-operative society is provided in section 2(19) of the Act. As per the provisions of section 2(19), "co-operative society" means a co-operative society registered under the Co-operative societies ... state for the registration of the cooperative society. When the provisions of Page 30 of 36 Akshaya Co-Op credit society Limited & others. section 2(19) of the Act were applied to the appellant society, it was observed that the appellant society was registered u/s. 8 (section

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 161/PAN/2023[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

operative engaged in the business of providing credit facilities to its members. The definition of "co-operative society is provided in section 2(19) of the Act. As per the provisions of section 2(19), "co-operative society" means a co-operative society registered under the Co-operative societies ... state for the registration of the cooperative society. When the provisions of Page 30 of 36 Akshaya Co-Op credit society Limited & others. section 2(19) of the Act were applied to the appellant society, it was observed that the appellant society was registered u/s. 8 (section

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 160/PAN/2023[2018-19]Status: DisposedITAT Panaji28 Nov 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

operative engaged in the business of providing credit facilities to its members. The definition of "co-operative society is provided in section 2(19) of the Act. As per the provisions of section 2(19), "co-operative society" means a co-operative society registered under the Co-operative societies ... state for the registration of the cooperative society. When the provisions of Page 30 of 36 Akshaya Co-Op credit society Limited & others. section 2(19) of the Act were applied to the appellant society, it was observed that the appellant society was registered u/s. 8 (section

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 159/PAN/2023[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

operative engaged in the business of providing credit facilities to its members. The definition of "co-operative society is provided in section 2(19) of the Act. As per the provisions of section 2(19), "co-operative society" means a co-operative society registered under the Co-operative societies ... state for the registration of the cooperative society. When the provisions of Page 30 of 36 Akshaya Co-Op credit society Limited & others. section 2(19) of the Act were applied to the appellant society, it was observed that the appellant society was registered u/s. 8 (section

Akshaya Co-Operative Credit Society Limited, Karwar vs. Income Tax Officer, Ward - 1(1), Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 158/PAN/2023[2014-15]Status: DisposedITAT Panaji28 Nov 2025AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

operative engaged in the business of providing credit facilities to its members. The definition of "co-operative society is provided in section 2(19) of the Act. As per the provisions of section 2(19), "co-operative society" means a co-operative society registered under the Co-operative societies ... state for the registration of the cooperative society. When the provisions of Page 30 of 36 Akshaya Co-Op credit society Limited & others. section 2(19) of the Act were applied to the appellant society, it was observed that the appellant society was registered u/s. 8 (section

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2405/CHNY/2025[2018-19]Status: DisposedITAT Chennai28 Nov 2025AY 2018-19

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

आयकर अपील"य अ"धकरण,‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी जॉज" जॉज

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2404/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Nov 2025AY 2017-18

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

आयकर अपील"य अ"धकरण,‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी जॉज" जॉज

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2403/CHNY/2025[2016-17]Status: DisposedITAT Chennai28 Nov 2025AY 2016-17

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

आयकर अपील"य अ"धकरण,‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी जॉज" जॉज

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2402/CHNY/2025[2014-15]Status: DisposedITAT Chennai28 Nov 2025AY 2014-15

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2401, 2402, 2403, 2404 & 2405/Chny/2025 निर्धारण वर्ष/Assessment Years: 2013-14, 2014-15, 2016-17, 2017-18 & 2018-19 The Assistant Commissioner Of Income Tax, Circle-1, Cuddalore M/S. Kallakurichi-Ii Co- Vs. Operative Sugar Mills Ltd., A1, Kachirapalayam, Kallakurichi, Cuddalore - 606 207 (अपीलार्थी/Appellant) Pan: Aaaak 0655Q (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Ms. E. Pavuna Sundari, Cit प्रत्यर्थी की ओर से/Respondent By : Shri S. Venugopalan, Ca सुनवाई की तारीख/Date Of Hearing : 27.11.2025 घोषणा की तारीख/Date Of Pronouncement : 28.11.2025 आदेश/Order Per George George K: These Appeals Filed By The Revenue Are Directed Against The Five Separate Orders Of The Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi, All Dated 18.06.2025, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant Assessment Years Are 2013-14, 2014-15 & 2016-17 To 2018-19. 2. The Solitary Issue That Is Raised Is Whether The First Appellate Authority (Faa) Is Justified In Directing The Ao To Grant Deduction U/S.80P(2)(D) Of The Act On The Interest Income Received By The Assessee From Villupuram District Central Co- Operative Bank. 3. Brief Facts Of The Case Are As Follows: The Assessments Were Completed U/S.147 R.W.S.144 R.W.S.144B Of The Act For The

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80P(2)(a)Section 80P(2)(d)

आयकर अपीलीय अधिकरण, 'ए' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, CHENNAI श्री जॉर्ज जॉर्ज के, उपाध्यक्ष

Assistant Commissioner of Income Tax, Circle-1, Cuddalore vs. Kallakurichi-II Co-Operative Sugar Mills Ltd., Kachirapalayam

ITA 2401/CHNY/2025[2013-14]Status: DisposedITAT Chennai28 Nov 2025AY 2013-14

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. E. Pavuna Sundari, CITFor Respondent: Shri S. Venugopalan, CA
Section 147Section 250Section 80Section 80P(2)(a)Section 80P(2)(d)

आयकर अपील"य अ"धकरण,‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी जॉज" जॉज

Saunshi Urban Co-Op Credit Society Limited, Sanushi vs. Income Tax Officer, Ward-1(1), Hubli

ITA 876/BANG/2025[2018-19]Status: DisposedITAT Bangalore28 Nov 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharysaunshi Urban Co-Op Credit Society Ltd. 01 Saunshi Urban Co-Op Credit Society Ltd. Market Road Saunshi Saunshi 581 117 ………. Appellant [Pan: Aaaas5548Q]

For Appellant: Ms. Harsha JFor Respondent: Sri Subramanian
Section 234BSection 250Section 270A(2)Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

held that 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 Act, as being a co-operative society registered either under the Co- operative Societies Act, 1912 or under any other ... time being in force in any State for the registration of co- operative societies. Section 2(19) of the Act refers only to the factum of a co-operative society being registered under the 1912 Act or under the State law. [refer to paragraph 28 of the judgment

Rohit Chambers Premises Coop Society Limited, Mumbai vs. Assessing Officer, Mumbai

In the result, appeal filed by the Assessee stands allowed

ITA 5812/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhryassessment Year: 2018-19 M/S. Rohit Chambers Premises Assessing Officer, Coop Society Limited, Ward 26(1)(1), Janmabhoomi Marg, Kautilya Bhavan, G Block Vs. Horniman Circle, Fort, Mumbai Bkc, Bandra Kurla – 400001. Complex, Bandra (E), Pan – Aaaar44550K. Mumbai 400051. (Appellant) (Respondent) Present For: Assessee By : Shri Satish Mody, Ld. Ca Revenue By : Shri Praveen K. Srivastava, Ld. Sr. D.R. Date Of Hearing : 20.11.2025 Date Of Pronouncement : 28.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 16.03.2021, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2018-19. 2. In This Case, The Assessee By Filing Its Return Of Income On Dated 19.09.2018 Had Declared Gross Total Income Of Rs.26,69,680/- Under The Head Income From The Other Sources & Claimed The Same As Exempt Under Section 80P(2)(D) Of The Act.

For Appellant: Shri Satish Mody, Ld. CAFor Respondent: Shri Praveen K. Srivastava, Ld. Sr. D.R
Section 119Section 139Section 2(19)Section 250Section 80Section 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

Vihan Vibhag Credit Co-Operative Society Ltd., Surat vs. ITO, Ward 2(2)(5), Surat

In the result, the appeal of the assessee is allowed

ITA 707/SRT/2025[2017-18]Status: DisposedITAT Surat27 Nov 2025AY 2017-18

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.707/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Vihan Vibhag Credit Co-Operative Vs. Ito, Society Ltd., Ward – 2(2)(5), At & Po: Vihan, Tal – Kamrej, Surat Tapi – 394320, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabav5113F (Appellant) (Respondent) Appellant By Shri Akshay M. Modi, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 17/11/2025 Date Of Pronouncement 27/11/2025

Section 143(2)Section 143(3)Section 250Section 253(3)Section 271(1)(c)Section 80PSection 80P(2)(d)

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE MS. SUCHITRA RAGHUNATH KAMBLE, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

Shree Raj Crystal Co Op Housing Society Ltd, Mumbai vs. ITO Waqrd 42(1)(5), Mumbai

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

ITA 5769/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry, Jm Shree Raj Crystal Co-Op. Asst. Director Of Income Housing Society Ltd. Tax, Cpc, Bengaluru Royal Complex, Chandawarkar Vs. Road & Eksar Road Junction, Borivali West, Mumbai 400091. Pan/Gir No. Aaas7159K (Appellant) : (Respondent) Assessee By : Shri Bhavesh Gala/Devang Divech Respondent By : Shri Praveen K. Srivastav, Sr. Dr Date Of Hearing : 19.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per Narender Kumar Choudhry, J M:

For Appellant: Shri Bhavesh Gala/DevangFor Respondent: Shri Praveen K. Srivastav, SR
Section 143(1)Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(d)

Crystal Co-op. Housing Society Ltd. 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

Ahmednagar Zilla Gramsevakanchi Sahakar Patsanstha Maryadit, Ahilyanagar vs. PCIT, Pune-1, Pune

In the result, the appeal of the assessee is allowed

ITA 1301/PUN/2025[2020-21]Status: DisposedITAT Pune25 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1301/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Ahmednagar Zilla Gramsevakanchi Sahakari Patsanstha Maryadit, 1, Opp. Sardar Patel Karyala, Behind Vs. Ketkar Hospital, Ahilyanagar-414001 The Pr. Cit, Pune-1 Pan : Aaaaa6582G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Shri Prasad S Bhandari Shri Amol Khairnar 11-09-2025 25-11-2025 आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 22.03.2025 Of The Ld. Principal Commissioner Of Income Tax, Pune-1 (“Pcit)” Passed U/S 263 Of The Income Tax Act, 1961 (The “Act”) Pertaining To Assessment Year (“Ay”) 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune -1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Fact That Interest On The Deposits Made By A Co-Operative Society With The Co-For Operative Bank Is Eligible Deduction Under Section 80P Of The Act. Hence, The Impugned Order Under Section 263 May Please Be Squashed. 2. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune 1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Submission Made By The Assessee Society & The Judgments Of Hon'Ble Jurisdictional Pune

For Appellant: Department byFor Respondent: Date of hearing
Section 143(2)Section 143(3)Section 263Section 56Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

rendered otiose". 7.2 As regards the question whether all the co-operative banks are primarily "co-operative societies" within the meaning of section 2(19) of the Income-tax Act to allow deduction u/s.80P(2)(d) of the Act on the interest earned from such co-operative banks ... first examined whether a 'co-operative bank' is akin to a 'co-operative society' mentioned in section 2(19) or section 80P(2)(d) of the Act. Hon'ble High Court of Karnataka has answered this issue against the assessee and in favour of revenue, at para

Sukhsagar Co Operative Credit Society Ltd, Mumbai vs. Income Tax Officer Ward 32(1)(1), Mumbai

ITA 4336/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Kumar Kale, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R
Section 147Section 250Section 56Section 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

Sukhsagar Co Operative Credit Society Ltd, Mumbai vs. Income Tax Officer Ward 32(1)(1), Mumbai

The appeal of the assessee is allowed in the

ITA 4335/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Nov 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Kumar Kale, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R
Section 147Section 250Section 56Section 80PSection 80P(1)Section 80P(2)(d)

investments, and (ti) 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

Gmedapadu Pacs, Gmedapadu vs. ITO, Ward-1, Kakinada

ITA 574/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.574/Viz/2025 ("नधा"रण वष"/Assessment Year: 2020-21) G Medapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Sri Kss Sarma, Ca राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 16/10/2025 Hearing: घोषणा क" तार"ख/Date Of 14/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

For Appellant: Sri KSS Sarma, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

आयकर अपील"य अ"धकरण, "वशाखपटनम पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam, “DIVN” Bench, Visakhapatnam Before Shri Manjunatha

Mumbai Mint Employees Cooperative Credit Society Ltd, Mumbai vs. Income Tax Officer 17 2 4 Mumbai, Mumbai

In the result, the assessee’s appeal is allowed

ITA 5706/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 M/S. Mumbai Mint Income Tax Officer- Employees’ Co-Operative 17(2)(4), Credit Society Ltd., Room No.112, 1St Floor, Vs. I.G. Mint, S.B. Road, Fort, Kautilya Bhavan, Mumbai – 400 001 C-41 To C-43, G Block, Pan: Aaaat8304P Bandra (East), Mumbai - 400061 (Appellant) (Respondent) Present For: Assessee By : Shri Mandar Vaidya, Ld. A.R. Revenue By : Shri Praveen K. Srivastav, Ld. Sr. D.R. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 05.08.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax, (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2017- 18. 2. In This Case, The Assessee Has Claimed Deduction U/S 80P Of The Act To Tune Of Rs.17,05,275/- Being Income Earned From Co- Operative Banks, By Filing Return Of Income On 01.11.2017 Declaring Income As Rs. “Nil”. The Ao Vide Assessment Order Dated 15.12.2019, Disallowed The Said Deduction Claimed By Holding That Benefit On The Amount Of Rs.17,05,275/- U/S 80P(2)(A)(I) Or 80P2(D)

For Appellant: Shri Mandar Vaidya, Ld. A.RFor Respondent: Shri Praveen K. Srivastav, Ld. Sr. D.R
Section 250Section 80PSection 80P(1)Section 80P(2)(a)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