OLAVANNA SERVICE CO-OPERATIVE BANK LIMITED,CALICUT vs. ITO, WARD-2(3), KOZHIKODE

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singholavanna Service Co-Op. Bank Ltd. The Income Tax Officer Olavanna Post Office Ward - 2(3), Kozhikode Vs. Kozhikode 673019 [Pan: Aaaao3624P] (Appellant) (Respondent)

Section 80P of the Act. The point of dispute here is that deposits are collected from nominal members and non-members who don't have say in running of the appellant society and any right on the profits of the appellant society and thus no identity between contributors to the surpluses and participators in the surpluses and thus the test