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“Section 2(24)(viia)”

Section References (mined)Section 2Section 2(24)(viia)28 judgments

INCOMETAX OFFICER, WARD-1(1), TIPTUR vs. SRIUDAYARAVI CREDIT CO-OP, TIPTUR

In the result, appeals of the Revenue are dismissed

ITA 2095/BANG/2024[2018-19]Status: DisposedITAT Bangalore14 Nov 2025AY 2018-19
Section 2(24)(viia)Section 80PSection 80P(2)(a)Section 80P(4)

opposed to facts of the case in\nallowing the entire deduction u/s 80P(2)(a)(i) of the Act.\n2.\nAs per section 2(24)(viia)- Profits and Gains of any business of\nbanking(including providing credit facilities) carried on by a\nco-operative society with its members is \"income

INCOMETAX OFFICER, WARD-1, TIPTUR vs. SRI UDAYRAVI CREDIT CO-OP, TIPTUR

ITA 2094/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 Nov 2025AY 2017-18

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 2(24)(viia)Section 80PSection 80P(2)(a)Section 80P(4)

opposed to facts of the case in allowing the entire deduction u/s 80P(2)(a)(i) of the Act. 2. As per section 2(24)(viia)- Profits and Gains of any business of banking(including providing credit facilities) carried on by a Co-operative society with its members is "income

EKTA SAHAKARI PATPEDHI MARYADIT,VIRAR vs. INCOME TAX OFFICER, ASSESSMENT UNIT, NEW DELHI

In the result, both the above appeals are allowed

ITA 106/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Mar 2025AY 2020-21
For Appellant: Shri Bhupendra Shah, ARFor Respondent: Shri Manish Ajudiya (Sr. DR)
Section 143Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

Copies of all such decisions is enclosed herewith for your record their all the decisions are came after amendment of Section 80P & section 2(24)(viia) w.e.f. 2007.\n7.4 As regards deduction u/s 80P(2)(d) from Interest earned from other Co-operative banks, it was stated that Co-operative

EKTA SAHAKARI PATPEDHI MARYADIT,VIRAR vs. INCOME TAX OFFICER, ASSESSMENT UNIT, NEW DELHI

In the result, both the above appeals are allowed

ITA 105/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Mar 2025AY 2018-19
For Appellant: \nShri Bhupendra Shah, ARFor Respondent: \nShri Manish Ajudiya (Sr. DR)
Section 143Section 143(3)Section 234ASection 80P(2)(a)Section 80P(2)(d)

Copies of all such decisions is enclosed herewith for your record their all the decisions are came after amendment of Section 80P & section 2(24)(viia) w.e.f. 2007.\n7.4 As regards deduction u/s Section 80P(2)(d) from Interest earned from other Co-operative banks, it was stated that

KARIKUNNAM SERVICE CO-OPERATIVE BANK LTD,THODUPUZHA vs. ITO, WARD-1& TPS, THODUPUZHA

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

ITA 364/COCH/2024[2017-2018]Status: DisposedITAT Cochin17 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Arun Raj S, AdvocateFor Respondent: Smt. Girly Albert, Snr. DR
Section 142Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

record. 7. As seen from the finding given in page 4 of the assessment order, which reads as follows: “Therefore, as per section 2(24)(viia) of the Income Tax Act,1961 inserted by the Finance Act, 2006, w.e.f. 1-4- 2007, the profits and gains of assessee's business

KALIKAVU SERVICE CO-OPERATIVE BANK LIMITED,KALIKAVU vs. ITO, WARD-2, TIRUR

Appeal of the assessee is hereby allowed

ITA 375/COCH/2024[2018-2019]Status: DisposedITAT Cochin26 Sept 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Hussain, AdvocateFor Respondent: Smt. Girly Albert, Sr. D.R
Section 2(24)(viia)Section 5Section 80Section 80PSection 80P(2)Section 80P(4)

under the purview of section 80P(4) of the Act and therefore not eligible for deduction u/s 80P of the Act. As per section 2(24)(viia) of the Act income earned from member by co-op society engaged in banking activity is also included in the definition of income

KALIKAVU SERVICE CO-OPERATIVE BANK LIMITED,KALIKAVU vs. ITO, WARD-2, TIRUR

Appeal of the assessee is hereby allowed

ITA 374/COCH/2024[2008-2009]Status: DisposedITAT Cochin26 Sept 2024AY 2008-2009

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Hussain, AdvocateFor Respondent: Smt. Girly Albert, Sr. D.R
Section 2(24)(viia)Section 5Section 80Section 80PSection 80P(2)Section 80P(4)

under the purview of section 80P(4) of the Act and therefore not eligible for deduction u/s 80P of the Act. As per section 2(24)(viia) of the Act income earned from member by co-op society engaged in banking activity is also included in the definition of income

MILLENIUM BUILDHOME PRIVATE LIMITED,KOTA vs. ITO(TDS), KOTA

In the result, the appeal of the assessee is stands partly allowed with no 6

ITA 866/JPR/2024[2016-17,2017-18,2018-19]Status: DisposedITAT Jaipur20 Aug 2024
For Appellant: Shri Rajendra Sisodiya, AdvFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 194Section 201Section 201(1)

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC’’ JAIPUR Jh lanhi xkslkbZ] U

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 699/MUM/2024[2018-19]Status: DisposedITAT Mumbai07 Aug 2024AY 2018-19

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

under any other law for the time being in force in any State for the registration of co-operative societies ; Section 2(24)(viia) of the Act provides that income includes- “2(24)(viia)- The profits and gains of any business of banking(including providing credit facilities) carried

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 698/MUM/2024[2017-18]Status: DisposedITAT Mumbai07 Aug 2024AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

under any other law for the time being in force in any State for the registration of co-operative societies ; Section 2(24)(viia) of the Act provides that income includes- “2(24)(viia)- The profits and gains of any business of banking(including providing credit facilities) carried

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 697/MUM/2024[2014-15]Status: DisposedITAT Mumbai07 Aug 2024AY 2014-15

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

under any other law for the time being in force in any State for the registration of co-operative societies ; Section 2(24)(viia) of the Act provides that income includes- “2(24)(viia)- The profits and gains of any business of banking(including providing credit facilities) carried

INCOME TAX OFFICER WARD-26(2)(1), MUMBAI, MUMBAI vs. STATE BANK OF INDIA EMPLOYEES M.S. PATEL CO-OP CREDIT SOCIETY LTD, MUMBAI

ITA 4853/MUM/2023[2017-18]Status: DisposedITAT Mumbai24 Jul 2024AY 2017-18

Bench: Shri Amarjit Singh & Shri Rahul Chaudharyito, Ward -26(2)(1) Vs. State Bank Of India Room No. 234, G Block, Employees M.S. Patel Kautilya Bhavan, Bkc, Co-Op Credit Society Ltd. Bandra (East) 3Rd Floor, State Bank Mumbai – 400051 Building, Sbi Mumbai Main Branch, Samachar Marg, Near Horniman Circle, Fort, Mumbai - 400023 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaas9621A Appellant .. Respondent Appellant By : H.M. Bhatt Respondent By : Hemant Shah Date Of Hearing 14.05.2024 Date Of Pronouncement 24.06.2024 आदेश / O R D E R Per Amarjit Singh, Am: The Present Appeal Filed By The Revenue Are Directed Against The Order Passed By The Cit(A) Nfac For A.Y. 2017-18 Of The Income Tax Act 1961. The Revenue Has Raised The Following Grounds Before Us:

For Appellant: H.M. BhattFor Respondent: Hemant Shah
Section 143(2)Section 2(24)Section 5Section 63Section 64Section 80PSection 80P(2)(a)Section 80P(4)

P a g e | 1 ITO, Ward-26(2)(1) Vs. State Bank of India Employees M.S. Patel Coop. Credit

SREE KANYAKA MUTUALLY AIDED CO-OP THRIFT CREDIT AND MARKETG. SOCIETY LIMITED,HINDUPUR vs. INCOME TAX OFFICER, WARD 1, HINDUPUR

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

ITA 224/HYD/2024[2018-19]Status: DisposedITAT Hyderabad22 Jul 2024AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia

For Appellant: Shri D. Shree Raksha, CAFor Respondent: Shri Shakeer Ahamed, DR
Section 143(3)Section 56Section 80PSection 80P(2)(a)

conclusion arrived at from the amendment to the Income Tax Act, 1961, effected by the Finance Act, 2006, w.e.f. 01.04.2007, wherein section 2(24)(viia) has been inserted and the definition of income, inter-alia, has also been defined as “the profit and gains of any business of Banking (including

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY,MUMBAI vs. ITO, WARD-28(1)(3), MUMBAI

In the result, Tax Appeals are dismissed

ITA 600/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Jun 2024AY 2012-13

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2012-13 M/S. Cidco Employees Ward 28(1)(3), 3Rd Floor, Co. Op. Credit Society Ground Floor, Tower No. 6, Vs. Cidco Bhavan, Vashi Railway Station, Cbd- Belapur, Commercial Complex, Navi Mumbai- 400614. Mumbai- 400703. Pan: Aaaac2230N (Appellant) (Respondent) Present For : Assessee By : Shri Bhupendra Shah, A.R. Revenue By : Shri R. R. Makwana- Sr. D.R.

For Appellant: Shri Bhupendra Shah, A.RFor Respondent: Shri R. R. Makwana- SR. D.R
Section 143(1)Section 143(3)Section 148Section 2(24)(viia)Section 234BSection 250Section 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Appellant u/s.80P over the years and has continued to allow the same even after the insertion of Section 80P (4) and Section 2(24)(viia) with effect from 1st April 2007 on the statute book by Finance Act 2006. However, the AO has disturbed the said position in the current

ITO-28.3.1, MUMBAI vs. VAIBHAV CO OP CREDIT SOCIETY, GHANSOLI ,

ITA 46/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 May 2024AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2014-15 Assessment Year: 2018-19 & Assessment Year: 2021-22

For Appellant: Shri Malay J. GosraniFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 143Section 143(1)Section 143(3)Section 154Section 36(1)(via)Section 80PSection 80P(2)(a)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL

ITO-28.3.1, MUMBAI vs. VAIBHAV CO OP CREDIT SOCIETY, GHANSOLI

ITA 44/MUM/2024[2018]Status: DisposedITAT Mumbai28 May 2024

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2014-15 Assessment Year: 2018-19 & Assessment Year: 2021-22

For Appellant: Shri Malay J. GosraniFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 143Section 143(1)Section 143(3)Section 154Section 36(1)(via)Section 80PSection 80P(2)(a)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL

ITO-28.3.1, MUMBAI vs. VAIBHAV CO OP CREDIT SOCIETY, GHANSOLI

ITA 298/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 May 2024AY 2021-22

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2014-15 Assessment Year: 2018-19 & Assessment Year: 2021-22

For Appellant: Shri Malay J. GosraniFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 143Section 143(1)Section 143(3)Section 154Section 36(1)(via)Section 80PSection 80P(2)(a)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL

MUDUR VYAVASAYA SEVA SAHAKARI SANGHA LTD., ,UDUPI vs. INCOME TAX OFFICER, WARD-1 & TPS, UDUPI

ITA 299/BANG/2024[2020-21]Status: DisposedITAT Bangalore14 May 2024AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2020-21

For Appellant: Shri Mahesh R. Uppin, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 143(1)Section 18Section 2(24)(viia)Section 56Section 80GSection 80PSection 80P(2)(a)Section 8P(2)(d)

referred to the scrutiny assessment order for AY 2018-19 and observed that Finance Act, 2006 inserted section 2(24)(viia) w.e.f. AY 2007-08 to include profits and gains of any business of banking Page 3 of 16 (including providing credit facilities) carried on by a co-operative society

BANNANJE GRAHAKARA VIVIDHODDESHA SAHAKARA SANGHA LTD., ,UDUPI vs. INCOME TAX OFFICER, WARD-1, & TPS, , UDUPI

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

ITA 79/BANG/2024[2016-17]Status: DisposedITAT Bangalore06 May 2024AY 2016-17

Bench: Shri George George Kshri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Shri Mahesh R Uppin, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 5

Person' under section 2(31 )(e), a co-operative society is an entity liable for income tax. The Finance Act, 2006 inserted section 2(24)(viia) with effect from assessment year 2007-08 to include, "the profits and gains of any business of banking (including providing credit facilities) carried

MEHSANA TALUKA MADHYAMIK TEACHERS CREDIT & CONSUMERS SAHAKARI MANDALI LTD,MEHSANA vs. THE ITO, WARD-2, PRESENT WARD-1, MEHSANA

In the result, appeal of the assessee is partly allowed

ITA 6/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2017-18

Bench: Shri Waseem Ahmed (Accountant Member), Ms. Madhumita Roy (Judicial Member)

For Appellant: Shri Hasmukh V. Doshi, A.RFor Respondent: Shri Sudhendu Das, CIT-D.R. &
Section 57Section 80Section 80P(2)(d)

restate that for the purposes of Section 80P of the Act, the principle of mutuality has been obliterated in view of insertion of Section 2(24) (viia) of the Act by Finance Act, 2006 and such principles thus no longer serve as strict guiding principle to test the relief eligible

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