Which cases are most cited on Section 80P(2)(a)(i)?

Totgars Co-operative Sale Society Ltd. v. ITO (322 ITR 283) — 1,283 citing judgments; Pr. CIT v. Totagars (395 ITR 611) — 1,074 citing judgments; Mavilayi Service Co-operative Bank Ltd. v. CIT (431 ITR 1) — 999 citing judgments; State Bank Of India v. CIT (389 ITR 578) — 817 citing judgments; Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society (392 ITR 74) — 762 citing judgments.

How many judgments are there on Section 80P(2)(a)(i)?

BharatTax indexes 2,347 ITAT, High Court and Supreme Court judgments that turn on Section 80P(2)(a)(i) of the Income Tax Act, 1961.

Section 80P(2)(a)(i) of the Income Tax Act

Income-tax Act, 2025: s.149

Section 80P(2)(a)(i) falls under section 80P of the Income-tax Act, 1961, which corresponds to section 149 (Deduction in respect of income of co-operative societies) of the Income-tax Act, 2025.

Read section 149 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 80P(2)(a)(i) is Totgars Co-operative Sale Society Ltd. v. ITO (322 ITR 283), cited in 1,283 of the 2,347 judgments on BharatTax that turn on this section.

Leading authorities on Section 80P(2)(a)(i)

Totgars Co-operative Sale Society Ltd. v. ITO

322 ITR 283 · 2010 · Supreme Court

1,283

citing judgments

The interest income earned by a cooperative society from investing its surplus funds in fixed deposits with banks is not "derived from" its eligible business activities and is taxable as "income from other sources" under Section 56, thus not qualifying for deduction under Section 80P.

Pr. CIT v. Totagars

395 ITR 611 · 2017 · High Court

1,074

citing judgments

Interest income earned by a cooperative society from surplus deposits or investments held with a cooperative bank is not eligible for deduction under Section 80P(2)(d) of the Act.

Mavilayi Service Co-operative Bank Ltd. v. CIT

431 ITR 1 · 2021 · Supreme Court

999

citing judgments

Section 80P(4) serves as a proviso to Section 80P(1) and (2), excluding only cooperative banks that are cooperative societies and possess an RBI license for banking business. Its purpose is to exclude cooperative banks operating like commercial banks that lend money to the public.

State Bank Of India v. CIT

389 ITR 578 · 2016 · High Court

817

citing judgments

Income arising from a cooperative society's surplus funds invested in short-term deposits and securities is not attributable to the society's core activities and, therefore, is not eligible for exemption under Section 80P(2)(a)(i) of the Income-tax Act.

Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society

392 ITR 74 · 2017 · High Court

762

citing judgments

Interest income earned by a cooperative society from its investments or surplus deposits with a cooperative bank is eligible for deduction under Section 80P(2)(d) of the Income-tax Act, 1961.

Subramanian and Anr. v. Siemens India Ltd. and Anr.

156 ITR 11 · 1985 · High Court

541

citing judgments

When there is a conflict between the decisions of non-jurisdictional High Courts, the view that favors the assessee should be preferred.

Tumkur Merchants Souharda Credit Cooperative Ltd. v. ITO

230 Taxmann 309 · 2015 · High Court

527

citing judgments

A cooperative society is eligible for deduction under Section 80P(2)(a)(i) if it is engaged in cooperative activities. It also clarifies the allowability of deduction under Section 80P(2)(d) for interest income received from investments made in cooperative banks, after duly considering the Supreme Court's decision in Totgars Co-operative Sale Society Ltd.

Citizen Co-operative Society Ltd. v. ACIT

397 ITR 1 · 2017 · Supreme Court

499

citing judgments

A co-operative credit society engaged in banking business with the general public, accepting deposits from non-members and advancing loans to non-members, is treated as a co-operative bank. Such a society falls under the exclusionary clause of Section 80P(4) and is not eligible for deduction under Section 80P(2)(a)(i).

Totgar's Co-operative Sale Society Ltd. v. ITO

188 Taxmann 282 · 2010 · Supreme Court

486

citing judgments

Interest income earned by a co-operative society from investments, particularly with co-operative banks, is not eligible for deduction under Section 80P as it is not attributable to the core business activities of the society and constitutes "other income", not "profits and gains of business".

CIT v. Andhra Pradesh State

200 Taxmann 220 · 2011 · High Court

348

citing judgments

Interest earned by a Co-operative Society from investing fixed deposits in banks is entitled to a deduction under Section 80P(2)(a)(i) of the Income-tax Act.

Judgments on Section 80P(2)(a)(i)

Vihan Vibhag Credit Co-Operative Society Ltd., Surat vs. ITO, Ward 2(2)(5), Surat

In the result, the appeal of the assessee is allowed

ITA 707/SRT/2025[2017-18]Status: DisposedITAT Surat27 Nov 2025AY 2017-18

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.707/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Vihan Vibhag Credit Co-Operative Vs. Ito, Society Ltd., Ward – 2(2)(5), At & Po: Vihan, Tal – Kamrej, Surat Tapi – 394320, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabav5113F (Appellant) (Respondent) Appellant By Shri Akshay M. Modi, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 17/11/2025 Date Of Pronouncement 27/11/2025

Section 143(2)Section 143(3)Section 250Section 253(3)Section 271(1)(c)Section 80PSection 80P(2)(d)

Bodipatti Primary Agriculture Co Operative Credit Society, Tirupur vs. The Income Tax Officer, Ward 2(4), Tirupur

ITA 2599/CHNY/2025[2019-20]Status: DisposedITAT Chennai26 Nov 2025AY 2019-20

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2599/Chny/2025 निर्धारण वर्ष/Assessment Year: 2019-20

Puthiyakavu Service Cooperative Bank Ltd, Kollam vs. ITO, Ward-2, Alappuzha

In the result, all three appeals of the assessee are allowed

ITA 790/COCH/2025[2022-23]Status: DisposedITAT Cochin25 Nov 2025AY 2022-23

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Rajakanan, AdvFor Respondent: Smt. Leena Lal, Snr AR

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Puthiyakavu Service Cooperative Bank Ltd, Kollam vs. ITO, Ward-2, Alappuzha

In the result, all three appeals of the assessee are allowed

ITA 789/COCH/2025[2020-21]Status: DisposedITAT Cochin25 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Rajakanan, AdvFor Respondent: Smt. Leena Lal, Snr AR

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Puthiyakavu Service Cooperative Bank Ltd, Kollam vs. ITO, Ward-2, Alappuzha

In the result, all three appeals of the assessee are allowed

ITA 788/COCH/2025[2018-19]Status: DisposedITAT Cochin25 Nov 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Rajakanan, AdvFor Respondent: Smt. Leena Lal, Snr AR

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Ahmednagar Zilla Gramsevakanchi Sahakar Patsanstha Maryadit, Ahilyanagar vs. PCIT, Pune-1, Pune

In the result, the appeal of the assessee is allowed

ITA 1301/PUN/2025[2020-21]Status: DisposedITAT Pune25 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1301/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Ahmednagar Zilla Gramsevakanchi Sahakari Patsanstha Maryadit, 1, Opp. Sardar Patel Karyala, Behind Vs. Ketkar Hospital, Ahilyanagar-414001 The Pr. Cit, Pune-1 Pan : Aaaaa6582G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Shri Prasad S Bhandari Shri Amol Khairnar 11-09-2025 25-11-2025 आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 22.03.2025 Of The Ld. Principal Commissioner Of Income Tax, Pune-1 (“Pcit)” Passed U/S 263 Of The Income Tax Act, 1961 (The “Act”) Pertaining To Assessment Year (“Ay”) 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune -1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Fact That Interest On The Deposits Made By A Co-Operative Society With The Co-For Operative Bank Is Eligible Deduction Under Section 80P Of The Act. Hence, The Impugned Order Under Section 263 May Please Be Squashed. 2. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune 1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Submission Made By The Assessee Society & The Judgments Of Hon'Ble Jurisdictional Pune

For Appellant: Department byFor Respondent: Date of hearing

Section 143(2)Section 143(3)Section 263Section 56Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Raigad Zilla Parishad Karmachari Sahakari Patpedhi Maryadit Alibag, Alibag vs. Income Tax Officer 3, Panvel

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

ITA 2351/PUN/2025[2020-21]Status: DisposedITAT Pune24 Nov 2025AY 2020-21

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं/Ita No.2351/Pun/2025 धििेंारण वर्ा /Assessment Year: 2020-2021 Raigad Zilla Parishad Ito 3, Panvel Vs Karmachari Sankari Patpedhi Maryadit Alibag, Natraj Premises, 2Nd Floor, Pnp Nagar, Alibag, H.O, Alibag, Raigarh -402201 Maharashtra

For Appellant: Shri N.A. KulkarniFor Respondent: Shri Umesh Phade-

Section 142(1)Section 144Section 250Section 80PSection 80P(2)(a)

Baramati Taluka Sahakari Phalutpadam Sangh, Pune vs. ITO Ward-14(50, Pune

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2104/PUN/2025[2018-19]Status: DisposedITAT Pune24 Nov 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2103 & 2104/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Baramati Taluka V The Income Tax Officer, Sahakariphalutpadan Sangh, S Ward-14(5), Pune. At Pipmaliatpimpali Post Pimpali Taluka Baramati District Pune – 413102. Maharashtra. Pan: Aaatb5269Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod Shingte Revenue By Shri Arvind Renge – Addl.Cit(Virtual) Date Of Hearing 04/11/2025 Date Of Pronouncement 24/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2018-19 Dated 25.07.2025 & 07.08.2025 Respectively; Against The Order U/S.143(3) Dated 05.03.2021 & Penalty Order U/S.270A Of The Act, Dated 09.08.2021 Respectively.For The Sake Of Convenience

Section 143(3)Section 250Section 270ASection 80PSection 80P(2)(a)Section 80P(2)(d)

Baramati Taluka Sahakari Phalutpadam Sangh, Pune vs. ITO Ward-14(5), Pune

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2103/PUN/2025[2018-19]Status: DisposedITAT Pune24 Nov 2025AY 2018-19

Section 143(3)Section 250Section 270ASection 80PSection 80P(2)(a)Section 80P(2)(d)

Kuruvambalam Service Co Operative Bank Limited, Kuruvambalam vs. Income Tax Officer, National Faceless Assessment Centre, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 816/COCH/2025[2020-21]Status: DisposedITAT Cochin21 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2020-21 Kuruvambalam Service Co-Op. Bank Ltd. .......... Appellant Chemmalassery, Malappuram 679328 [Pan: Aacak3292M] Vs. The Income Tax Officer, Tirur .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 02.09.2025 For Assessment Year (Ay) 2020-21. 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. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant Filed The Return Of Income For Ay 2020-21 On 10.02.2021 Declaring Income Of Rs. 1,00,160/- After Claiming Deduction Of Rs. 37,89,750/-

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 56Section 63Section 64Section 80P(2)(a)

The Ezhumzttoor Service Co-Operative Bank Ltd, Pathanmthitta vs. ITO, Ward-2, Thiruvalla

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

ITA 778/COCH/2025[2020-21]Status: DisposedITAT Cochin21 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2020-21 Ezhumattoor Service Co-Op. Bank Ltd. .......... Appellant 7-392, Ezhumattoor P.O., Malappally Pathanamthitta 689586 [Pan: Aafat6575K] Vs. The Income Tax Officer, Ward-2, Thiruvalla .......... Respondent Assessee By: Smt. Pooja V.M., Advocate Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 27.03.2025 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Return Of Income For Ay 2020-21 Was Filed On 30.12.2020 Declaring Total Income Of Rs. 25,120/- After Claiming Deduction U/S. 80P(2)(A)(I) Of The Income Tax Act, 1961 (The Act). Against The Said Return Of 2 Ezhumattoor Service Co-Op. Bank Ltd. Income, The Assessment Was Completed By The Assessment Unit Of Income Tax Department (Hereinafter Called "The Ao") Vide Order Dated 27.09.2022 Passed U/S. 143(3) R.W.S. 144B Of The Act At Total Income Of Rs. 57,08,630/-. While Doing So, The Ao Denied Deduction U/S. 80P In Respect Of Interest Income Of Rs. 56,83,510/- Placing Reliance On The Decision Of The Hon'Ble Apex Court In The Case Totgar’S Co-Operative Sale Society Ltd. V. Ito [2010] 322 Itr 283 (Sc).

For Appellant: Smt. Pooja V.M., AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Vythiri Service Co-Operative Bank Ltd., Vythiri vs. ITO, Ward 1, Kalpetta P.O

In the result, the appeal filed by the assessee is allowed

ITA 627/COCH/2025[2023-24]Status: DisposedITAT Cochin21 Nov 2025AY 2023-24

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2023-24 Vythiri Service Co-Op. Bank Ltd. .......... Appellant Vythiri P.O., Wayanad 673576 [Pan: Aaaav8077B] Vs. The Income Tax Officer, Ward-1, Kalpetta .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 04.07.2025 For Assessment Year (Ay) 2023-24. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant Filed The Return Of Income For Ay 2023-24 On 14.10.2023 Disclosing Income Of Rs. 1,46,100/- After Claiming Deduction U/S. 80P(2)(A)(I) Of The Income Tax Act, 1961 (The Act) Of Rs. 1,68,13,360/-. Against

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 40Section 63Section 64Section 80P(2)(a)

Shri Chatrapati Shivaji Vividoddeshagala Sahakari Sangha Niyamita Haliyal, Haliyal vs. Pr. Commissioner of Income Tax, Hubbali

ITA 1186/BANG/2025[2020-21]Status: DisposedITAT Bangalore21 Nov 2025AY 2020-21

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2020-21 M/S. Shri Chatrapati Shivaji Vividoddeshagala Vs. Pcit, Sahakari Sangha Niyamita, Hubli. Near Mlc Office, Bus Stand Road, Haliyal – 581 329, Karnataka. Pan : Aajas 9684 G Appellant Respondent Assessee By : Shri. Vinay K Kulkarni, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 30.10.2025 Date Of Pronouncement : 21.11.2025

For Appellant: Shri. Vinay K Kulkarni, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 139(1)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

Sukhsagar Co Operative Credit Society Ltd, Mumbai vs. Income Tax Officer Ward 32(1)(1), Mumbai

The appeal of the assessee is allowed in the

ITA 4335/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Nov 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Kumar Kale, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R

Section 147Section 250Section 56Section 80PSection 80P(1)Section 80P(2)(d)

M/S Peringalam Service Co-Operative Bank Ltd, Kannur vs. ITO, Ward 2, Kannur

In the result, the appeal filed by the assessee is allowed

ITA 787/COCH/2025[2018-19]Status: DisposedITAT Cochin20 Nov 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2018-19 Peringalam Service Co-Op. Bank Ltd. .......... Appellant Mukkilpeedika, Pullukkara, Kannur 670672 [Pan: Aabap0027A] Vs. The Income Tax Officer, Wd-2, Kannur .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 20.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 12.09.2025 For Assessment Year (Ay) 2018-19. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant Filed Return Of Income For Ay 2018-19 On 05.10.2018 Declaring Nil Income After Claiming Deduction U/S. 80P(2)(A)(I) Of The Income Tax Act, 1961 (The Act) Of Rs. 10,70,510/-. Against The Said Return Of 2 Peringalam Service Co-Op. Bank Ltd. Income, The Assessment Was Completed By The National E- Assessment Centre, Delhi (Hereinafter Called "The Ao") Vide Order Dated 20.04.2021 Passed U/S. 143(3) R.W.S. 144B Of The Act At Total Income Of Rs. 10,70,510/-. While Doing So, The Ao Had Disallowed The Claim For Deduction U/S. 80P(2)(A)(I) Of Rs. 10,70,510/- In Respect Of Interest Income Received From Banks.

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 63Section 64Section 80P(2)(a)

Income Tax Officer, Kota vs. Kota Karamachari Sahakari Samiti Limited, Kota

Appeal is allowed

ITA 1432/JPR/2025[2018-19]Status: DisposedITAT Jaipur20 Nov 2025AY 2018-19

For Appellant: Shri P.C.Parwal, FCAFor Respondent: Sh. Rajesh Ojha, CIT

Section 143(1)Section 143(2)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

Avittathur Service Cooperative Bank Ltd No 706, Thrissur vs. Ward 1(1), Thrisssur, Thrissur

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

ITA 800/COCH/2025[2017-18]Status: DisposedITAT Cochin19 Nov 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2017-18 Avittahur Service Co-Op. Bank Ltd. .......... Appellant Avittathur, Thrissur 680683 [Pan: Aacaa0257E] Vs. The Income Tax Officer, Ward-2(1), Thrissur ......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 07.11.2025 Date Of Pronouncement: 19.11.2025 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 (Nfac) Dated 20.08.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The 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. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 80PSection 80P(2)(a)

The Thimiri Service Co-Operative Bank Ltd, Kasaragod vs. ITO Ward, Kasaragod

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

ITA 731/COCH/2025[2009-10]Status: DisposedITAT Cochin19 Nov 2025AY 2009-10

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2009-10 The Thimiri Service Co-Op. Bank Ltd. .......... Appellant Nhanumaki, Chervathur, Kasaragod 671313 [Pan: Aabat0462H] Vs. The Income Tax Officer, Wd-2, Kasaragod .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 04.11.2025 Date Of Pronouncement: 19.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 20.08.2025 For Assessment Year (Ay) 2009-10. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant Had Not Filed Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act). A Notice U/S. 148 Of The Act Was Issued To The Assessee On 30.10.2015. In Response

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 139(1)Section 143(3)Section 148Section 80PSection 80P(2)(a)

ITO-19(3)(1), Mumbai vs. The Jackson Coop Credit Society of the Employees of Western Railway Limited, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 2976/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Nov 2025AY 2018-19

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 142(1)Section 250Section 56Section 62Section 80PSection 80P(2)(a)

Shree Chalala VI Ka Seva Sahakari Mandali Ltd., Amreli vs. The ITO Ward 3(1)(4), Rajkot-Amreli., Rajkot

The appeal of the assessee is allowed

ITA 358/RJT/2025[2019-20]Status: DisposedITAT Rajkot17 Nov 2025AY 2019-20

Bench: Dr. Arjun Lal Saini, A Ccountant Member & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 358/Rjt/2025 िनधा"रण वष" / Assessment Year: (2019-20) Shree Chalala Vi Ka Seva Sahakari Vs. The Ito Ward 3(1)(4), Mandali Ltd. Aayakar Bhavan, Race Course Ring Chalala Haveli Road, Road, Dhari Amreli - 365630 Rajkot - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatas2273D (Appellant) (Respondent) Appellant By : Ms. Devina Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 27/08/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm; Captioned Appeal Filed By Assessee Pertaining To Assessment Year 2019-20, Is Directed Against Order Passed Under Section 250 Of The Income Tax Act, 1961 By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income Tax (Appeals), Dated 31/03/2025, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(1) Of The Act. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: - 1. The Learned Addl/Jcit (A)-1, Kolkata Erred In Confirming Action Of Cpc, Bangalore In Disallowing Claim Of Deduction Of Rs. 3,51,828/- U/S Sop Of The Act By Failing To Appreciate That Provisions Of Sec. 143(1)(A)(V) Do Not Provide For Denial Of Deduction U/S 80P Of The Act When The Return Of Income Is Not Filed Within Time Allowed U/S 139(1) Of The Act But U/S 139(4). 2. The Learned Addl/Jcit (A)-1, Kolkata Erred In Upholding Action Of The Cpc, Bangalore In Making Adjustment To The Returned Income Of The Appellant By Way Of Shree Chalala Vikas Seva Sahkari Mandli Ltd.

For Appellant: Ms. Devina Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR

Section 119(2)(b)Section 139(1)Section 139(4)Section 143(1)Section 143(1)(a)Section 250Section 80PSection 80P(2)(d)