THE DHAMAI COOPERATIVE AGRICULTURE SERVICE SOCIETY LIMITED,HOSHIARPUR vs. INCOME TAX OFFICER WARD, HOSHIARPUR

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.238/Asr/2023 Assessment Year: 2020-21

80P but the Ld. AO disallowed the deduction for violation of Section 80P(2)(d) of the the Act. In relation

THE KOT RAM DASS COOP. THIRFT & CREDIT SOCIETY LIMITED,JALANDHAR vs. INCOME TAX OFFICER WARD-2 (4), JALANDHAR

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.86/Asr/2021 Assessment Year: 2017-18

80P but the Ld. AO disallowed the deduction for violation of Section 80P(2)(d) of the the Act. In relation

M/S. THE FARIDKOT PRIMARY COOP AGRICULTURAL DEVELOPMENT BANK.LIMITED,FARIDKOT vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3, FEROZEPUR

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

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

disallowing the deduction claimed by the assessee u/s 80P while giving a wrong interpretation to the definition of Primary Co-operative Agricultural & Rural Development Bank as given in Explanation to section

THE DALLA CO OP AGRI MULTIPURPOSE SOCIETY LIMITED,JALANDHAR vs. INCOME TAX OFFICER WARD-, PHAGWARA

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 593/Asr/2025 Assessment Year: 2018-19 The Dalla Co-Op. Agri Vs. Ito, Ward (1), Multipurpose Society Ltd. C/O Phagwara. B.D. Bansal & Co. B-641, Ground Floor Near A Block Gurudwara Ranjit Avenue, Amritsar. [Pan:-Aacat2201M] (Appellant) (Respondent) Appellant By Sh. Lakshay Bansal, Ca Sh. Charan Dass, Sr. Dr Respondent By Date Of Hearing 22.01.2026 Date Of Pronouncement 23.03.2026

80P(2) (d) of the Act, ( as per details contained in para 3 of the assessment order) and the said claim of the assessee, has been disallowed by the AO due to the reasons that cooperative banks do not fall under the purview of cooperative society and are now governed by Banking Regulation Act, hence interest income arising from funds

THE BHANOKI CO-OP.AGRI.MULTIPUPOSE SOCIETY LTD, ,PHAGWARA vs. DEPUTY COMMISSIONER OF INCOME ATX , PHAGWARA

In the result, appeal of the assessee is allowed

Bench: Sh. N. K. Saini, Hon’Bleita No. 588/Asr./2017 : Asstt. Year : 2011-12 The Bhanoki Co-Op, Agri, Vs Dcit, Phagwara Multipurpose Society Ltd., Vpo Bhanoki, Phagwara (Appellant) (Respondent) Pan No. Aadat0546N Assessee By : Sh. Y.K. Sud, Ar Revenue By : Sh. M.S. Parmar, Dr Date Of Hearing : 15.01.2019 Date Of Pronouncement : 16.01.2019

disallowance of Rs. 177069/- under section u/s80-P of the Income Tax Act, 1961. ITA No. 588/Asr./2017 5 The Bhanoki Coop 8. Facts of the case in brief are that the assessee derived income from banking business and filed the return of income declaring nil income after claiming deduction under section 80P

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSAHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

disallowed by the AO, treating the said deduction as income of the assessee, under the head “income from other source”, by observing in paragraph – 5 of the order, that the assessee has earned interest income on investment made with Nationalised Bank, Scheduled Bank, Cooperative banks and assessee has also claimed the same as deduction u/s 80P

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSHAHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

disallowed by the AO, treating the said deduction as income of the assessee, under the head “income from other source”, by observing in paragraph – 5 of the order, that the assessee has earned interest income on investment made with Nationalised Bank, Scheduled Bank, Cooperative banks and assessee has also claimed the same as deduction u/s 80P

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSHAHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

disallowed by the AO, treating the said deduction as income of the assessee, under the head “income from other source”, by observing in paragraph – 5 of the order, that the assessee has earned interest income on investment made with Nationalised Bank, Scheduled Bank, Cooperative banks and assessee has also claimed the same as deduction u/s 80P

THE JASSOMAZARA COOP MULTIPUPOSE SOCIETY LIMITED,NAWANSHAHR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2, JALANDHAR

In the result, all the four appeal of the assessee are allowed for statistical purpose

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. Nos. 513 To 516/Asr/2024 Assessment Years: 2013-14, 2017-18, 2018-19 & 2020-21

disallowed by the AO, treating the said deduction as income of the assessee, under the head “income from other source”, by observing in paragraph – 5 of the order, that the assessee has earned interest income on investment made with Nationalised Bank, Scheduled Bank, Cooperative banks and assessee has also claimed the same as deduction u/s 80P

THE HOSHIARPUR CENTRAL COPREATIVE -BANK,HOSHIARPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE HOSHIARPUR, HOSHIARPUR

In the result, ground no. 1 of the assessee has not pressed, ground no-3 is

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

disallowance as made by the AO, the ld. CIT(A) observed that the assessee is not eligible in deduction of the second limb of section 36(1)(viia) of the Act which concerns itself with deduction computed @ 10% of aggregate average advance made rural branches of the assessee. To keeping in view, amended provision to section

MESRES ATHOULA CO-OP AGRICULTURE MULTIPURPOSE SERVICE SOCIETY LTD,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JALANDHAR

In the result, both the appeal filed by the assessee are dismissed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 80P(2)(a), which is wide enough to include such interest earned by the assessee society in its fold as also affirmed by the Hon'ble Karnataka High Court in the judgement cited supra. 5. The Ld CIT(A) has erred in not allowing to set off, as an alternative the average cost of funds from the said interest

M/S ATHOULA CO-OP AGRICLUTURE MULTIPURPOSE SERVICE SOCIETY LTD,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JALANDHAR

In the result, both the appeal filed by the assessee are dismissed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

section 80P(2)(a), which is wide enough to include such interest earned by the assessee society in its fold as also affirmed by the Hon'ble Karnataka High Court in the judgement cited supra. 5. The Ld CIT(A) has erred in not allowing to set off, as an alternative the average cost of funds from the said interest

THE HOSHIARPUR CENTRAL COOP. BANK LTD,HOSHIARPUR vs. THE DY COMMISSIONER OF INCOME TAX, HOSHIARPUR

Bench: Sh. N. K. Choudhry & Sh. O. P. Meena

disallowance could be made. Here it may also be relevant to state that section 36(1)(viia) is applicable to cooperative banks (other than those excluded) w.e.f. 01.04.2007, i.e., AY 2007-08 onwards. The assessee has not been shown to us as falling within the excluded categories, which we note to be the same as those saved u/s. 80P

THE DEPUTY COMMISSIONER OF INCOME TAX, HOSHIARPUR vs. HOSHIARPUR CENTRAL COOP. BANK LTD., HOSHIARPUR

Bench: Sh. N. K. Choudhry & Sh. O. P. Meena

disallowance could be made. Here it may also be relevant to state that section 36(1)(viia) is applicable to cooperative banks (other than those excluded) w.e.f. 01.04.2007, i.e., AY 2007-08 onwards. The assessee has not been shown to us as falling within the excluded categories, which we note to be the same as those saved u/s. 80P

THE ASSTT. COMMISSIONER OF INCOME-TAX, HOSHIARPUR vs. THE HOSIARPUR CENTRAL CO-OPERATIVE BANK LTD., HOSHIARPUR

Bench: Sh. N. K. Choudhry & Sh. O. P. Meena

disallowance could be made. Here it may also be relevant to state that section 36(1)(viia) is applicable to cooperative banks (other than those excluded) w.e.f. 01.04.2007, i.e., AY 2007-08 onwards. The assessee has not been shown to us as falling within the excluded categories, which we note to be the same as those saved u/s. 80P

THE HOSHIARPUR CENTRAL COOP. BANK LTD.,HOSHIARPUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, HOSHIARPUR

Bench: Sh. N. K. Choudhry & Sh. O. P. Meena

disallowance could be made. Here it may also be relevant to state that section 36(1)(viia) is applicable to cooperative banks (other than those excluded) w.e.f. 01.04.2007, i.e., AY 2007-08 onwards. The assessee has not been shown to us as falling within the excluded categories, which we note to be the same as those saved u/s. 80P

THE MUTHADA KHURD CO OPERATIVE AGRI MULTIPURPOSE SOCIETY LIMITED,JALANDHAR vs. INCOME TAX OFFICER WARD-1, PHAGWARA

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

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

80P of the Act. This is an admitted fact that the said return was filed belatedly on 14.10.2019. The "due date" for filing return of income under section 139 for the year under consideration was 30.09.2019. Therefore, while processing the return of income, AO has made prime-facie adjustment under section 143(1)(a) of the Act, and disallowed

THE MAHIL GAILAN COOPERATIVE AGRICULTURE SERVICE SOCIETY LIMITED,MAHIL GAILAN, SBS NAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, JALANDHAR

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

Bench: Sh. Udayan Dasgupta & Sh. Brajesh Kumar Singh

Section 80P of Income Tax Act, 1961. 2. That the Worthy Commissioner of Income Tax (Appeals)/ JCIT (Appeals)-10, Mumbai has wrongfully disallowed