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

disallowed the deduction for violation of Section 80P(2)(d) of the the Act. In relation to restriction u/s 80P(4

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

disallowed the deduction for violation of Section 80P(2)(d) of the the Act. In relation to restriction u/s 80P(4

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 NBI EMPLOYEES CO-OP NON-AGRICULTURAL THRIFT & CREDIT SOCIETY LIMITED ,JALANDHAR vs. PRINCIPAL COMMISIONER OF INCOME TAX-2, JALANDHAR

Bench: Sh. Ravish Sood & Dr. M. L. Meena

disallowance w.r.t. deduction claimed u/s 80P of the Income Tax Act, 1961 which was required to be added to its income as rightly observed by the Ld. Pr. CIT. As per provisions of section 80P(2)(d) of the Income Tax Act, 1961, the Co¬ operative Society is provided deduction under said section in respect of income

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

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

4. In his rival submission, the learned DR opposed the condonation of delay and stated that there was no reasonable cause. 5. In the present case, it appears that the impugned order was not served upon the assessee but on the counsel of the assessee. The said counsel could not inform the assessee and therefore the appeal before the learned

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,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 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 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(4

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(4

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(4

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(4

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

4) and (5)of section 139 of the Act, for the Asst year 2019-20. 15. As such considering all aspects of the matter , since it is clearly not ascertainable neither from the rectification order u/s 154 nor from the first appeal order ,the actual reasons for disallowance of claim u/s 80P

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

4. In spite of asessee's contention, the Ld CIT(A) has erred in keeping silent on the relevance of scope of words 'ATTRIBUTABLE' used in 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

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

4. In spite of asessee's contention, the Ld CIT(A) has erred in keeping silent on the relevance of scope of words 'ATTRIBUTABLE' used in 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

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

4 I.T.A. No. 106/Asr/2024 Assessment Year: 2021-22 No 14(iii+ iv) P & L account (Interest and dividend income) (ii) 5ii of BFLA (BP) + 5xiii of BFLA(OS). Hence deduction u/s 80P, SI. No. 11 was rightly restricted minimum of above 2.Thus, the disallowance of claim of deduction u/s 80P of the Act of Rs. 86,89,271/- is confirmed