M/S THURAYUR SERVICE CO -OP BANK LTD,KOZHIKODE vs. THE ITO WARD 2(1), KOZHIKODE

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

4) of Section 80P of the Act. The appellant is a co-operative credit society under Section 80P(2)(a)(i) of the Act whose primary object is to provide financial accommodation to its members who are all other co- operative societies and not members of the public. 15.14. Therefore, when the definition of “co-operative bank” in Section

M/S THURAYUR SERVICE CO -OP BANK LTD,KOZHIKODE vs. THE ITO WARD 2(1), KOZHIKODE

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

4) of Section 80P of the Act. The appellant is a co-operative credit society under Section 80P(2)(a)(i) of the Act whose primary object is to provide financial accommodation to its members who are all other co- operative societies and not members of the public. 15.14. Therefore, when the definition of “co-operative bank” in Section

M/S KOTTAYAM SERVICE CO-OP BANK LTD,KANNUR vs. ITO WARD 2, KANNUR

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

4) of Section 80P of the Act. The appellant is a co-operative credit society under Section 80P(2)(a)(i) of the Act whose primary object is to provide financial accommodation to its members who are all other co- operative societies and not members of the public. 15.14. Therefore, when the definition of “co-operative bank” in Section

M/S KOTTAYAM SERVICE CO-OP BANK LTD,KANNUR vs. ITO WARD 2, KANNUR

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

4) of Section 80P of the Act. The appellant is a co-operative credit society under Section 80P(2)(a)(i) of the Act whose primary object is to provide financial accommodation to its members who are all other co- operative societies and not members of the public. 15.14. Therefore, when the definition of “co-operative bank” in Section

EDAVILANGU SERVICE CO-OPERATIVE BANK LTD NO 3468,THRISSUR vs. ITO, WARD-2(1), THRISSUR

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

condone the delay in filing the appeals. 4. The brief facts of the case are that the assessee is a credit society providing credit facilities to its members. The assessee filed their return of income on 07/12/2018 declaring a Nil income and claimed the deduction u/s. 80P(2) of the Act. Thereafter the case was selected for complete scrutiny

EDAVILANGU SERVICE CO-OPERATIVE BANK NO 3468,THRISSUR vs. ITO, WARD-2(1), THRISSUR

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

condone the delay in filing the appeals. 4. The brief facts of the case are that the assessee is a credit society providing credit facilities to its members. The assessee filed their return of income on 07/12/2018 declaring a Nil income and claimed the deduction u/s. 80P(2) of the Act. Thereafter the case was selected for complete scrutiny

VILAVATTAM SERVICE CO-OP BANK LTD NO 337,THRISSUR vs. ITO WARD 2(3), THRISSUR

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

4) of Section 80P of the Act. The appellant is a co- operative credit society under Section 80P(2)(a)(i) of the Act whose primary object is to provide financial accommodation to its members who are all other co-operative societies and not members of the public. 15.14. Therefore, when the definition of “co-operative bank” in Section

VILAVATTAM SERVICE CO-OP BANK LTD NO 337,THRISSUR vs. ITO WARD 2(3), THRISSUR

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

4) of Section 80P of the Act. The appellant is a co- operative credit society under Section 80P(2)(a)(i) of the Act whose primary object is to provide financial accommodation to its members who are all other co-operative societies and not members of the public. 15.14. Therefore, when the definition of “co-operative bank” in Section

M/S. PARAVUR SERVICE CO-OPERATIVE BANK,KOLLAM vs. INCOME TAX OFFICER, WARD 2, KOLLAM

In the result, the appeal and stay petition filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K.Assessment Year: 2017-18

80P (2)(a) on their income as held by the Apex Court in the case of Mavilayil Service Co-operative Bank Ltd For the reasons stated in the above and also the grounds urged at the time of final hearing, it is just and necessary to set aside the Annexure Al M/s. Paravur Service Co-operative Bank Ltd., Thiruvananthapuram Page

THE KUNDARA PANCHAYATH SERVICE COOPERATIVE BANK LTD,KOLLAM vs. INCOME TAX OFFICER, WARD 4, KOLLAM

In the result, appeals filed by the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

section 80P as District Co-operative Banks are also Co-operative societies. The deduction u/s 80P would also be available even if the interest received is assessed as income from other sources. The Commissioner(Appeals) has hence erred in not following the binding precedent of the jurisdictional High court. 3. There is a delay of 136 days in filing these

THE KUNDARA PANCHAYATH SERVICE COOPERATIVE BANK LTD,KOLLAM vs. INCOME TAX OFFICER, WARD-4, KOLLAM

In the result, appeals filed by the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

section 80P as District Co-operative Banks are also Co-operative societies. The deduction u/s 80P would also be available even if the interest received is assessed as income from other sources. The Commissioner(Appeals) has hence erred in not following the binding precedent of the jurisdictional High court. 3. There is a delay of 136 days in filing these

THE KUNDARA PANCHAYATH SERVICE COOPERATIVE BANK LTD,KOLLAM vs. INCOME TAX OFFICER, WARD 4, KOLLAM

In the result, appeals filed by the assessee are allowed

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

section 80P as District Co-operative Banks are also Co-operative societies. The deduction u/s 80P would also be available even if the interest received is assessed as income from other sources. The Commissioner(Appeals) has hence erred in not following the binding precedent of the jurisdictional High court. 3. There is a delay of 136 days in filing these

M/S KADIRUR SERVICE CO-OP BANK LTD,KANNUR vs. ITO WARD 2, KANNUR

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

Bench: Smt. Beena Pillai & Shri Waseem Ahmedassessment Year : 2009-10 M/S. Kadirur Service Co- Operative Bank Ltd., The Income Tax Kadirur, Officer, Thalassery, Ward – 2, Kannur, Kannur. Kerala – 670 642. Vs. Pan: Aaffk6859E Appellant Respondent : Shri Arun Raj .S, Assessee By Advocate Revenue By : Shri Ilayaraja K.S, Sr. Dr

section 51 of the Limitation Act of 1963 in order to enable the courts to do substantial justice to parties by disposing of matters on de merits". The Page 6 of 16 expression “sufficient cause” employed by the Legislature is adequately elastic to enable the courts to apply the law in a meaningful manner which subserves the ends of justice

AYYANTHOLE PANCHAYATH SERVICE COOPERATIVE BANK LIMITED 471,KARIYATTUKARA vs. INCOME TAX OFFICER WARD 2(1), THRISSUR

In the result, the appeals filed by the assessee stand allowed

delays in filing these appeals, which were condoned by the tribunal. The Assessing Officer denied the deduction under Section 80P, and the CIT(A) granted partial relief.", "held": "The Tribunal, following the decision of the Hon'ble Supreme Court in Mavilayi Service Co-operative Bank Ltd. v. CIT, held that the assessee is entitled to the deduction under Section 80P

AYYANTHOLE PANCHAYATH SERVICE COOPERATIVE BANK LIMITED 471,KARIYATTUKARA vs. INCOME TAX OFFICER WARD 2(1), THRISSUR

In the result, the appeals filed by the assessee stand allowed

delay in all three cases is condoned, and the appeals are\nadmitted for adjudication on merits.\n3. The core issue across all the appeals relates to the disallowance of\ndeduction claimed under Section 80P of the Income-tax Act, 1961. We\ntake ITA No.208/Coch/2025 as lead case for narration of facts.\nITA No.208/Coch/2025- The assessee fled its return of income

ERAMALLOOR SERVICE CO-PERATIVE BANK LTDS NO.1175,CHERTHALA vs. ITO, WARD-1, ALAPPUZHA

In the result, the appeal by the assessee is dismissed

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

section 80P of the Act was never made by the assessee through filing of return or by filing a belated return through condonation of delay process, and therefore, the assessee lost its opportunity to make a valid claim for deduction. Being aggrieved, the assessee is in appeal before us. 6. During the hearing, the learned Authorised Representative (“learned AR”) submitted

AVINISSERY SERVICE CO-OPERATIVE BANK LTD,THRISSUR vs. ITO, WARD 2(1),THRISSUR, THRISSUR

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

condone the delay in filing the present appeal and proceeded to adjudicated the following grounds of appeal raised by the Assessee: “1. This is an Appeal by the assessee against the assessment order passed u/s 143(3) by the Ld. AO on 21/12/2018 and disallowed the deduction u/s 80 P. The appellant Avinissery Service Co-operative Bank Limited

PANTHEERANKAVE SERVICE CO-OPERATIVE BANK,KOZHIKODE vs. ITO,WARD -2(3), KOZHIKODE

In the result, the appeal filed by the assessee stands dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2017-18 Pantheerankav Service Co-Op. Bank Ltd. .......... Appellant Olavanna, Kozhikode 673019 [Pan: Aaaap6394F] Vs. Income Tax Officer, Ward-2(3), Kozhikode .......... Respondent Appellant By: Shri Arun Raj S., Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 04.06.2025 Date Of Pronouncement: 30.06.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 12.12.2024 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. The Appellant Had Not Filed Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) For Ay 2017-18. Based On The Information That The Appellant Made

4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. At the outset there is a delay in filing the present appeal by 92 days. The appellant filed a petition seeking condonation of delay on the ground that the delay had occurred on account of obtaining legal opinion on the merits of filing further