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)

Tarunsangar Vivedhoddeshagal Souhard Sahakari Limited, Bijapur vs. Income-Tax Officer, Ward-1 & Tps, Bijapur

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

ITA 695/BANG/2024[2020-21]Status: DisposedITAT Bangalore28 Jun 2024AY 2020-21

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Smt. Pratibha R., AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

Aashirwad (1) Co-Operative Housing Society Limited, Mumbai vs. Deputy Director of Income Tax, CPC Bengaluru

In the result, appeal of the assessee is allowed

ITA 729/MUM/2024[2022-23]Status: DisposedITAT Mumbai28 Jun 2024AY 2022-23

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(1)Section 2Section 4Section 56Section 80PSection 80P(2)Section 80P(2)(d)

Kumkum Kavita Cooperative Housing Society Limited, Mumbai vs. Income Tax Officer -27(1)(1), Mumbai (Current Jurisdiction), It-Office, Vasi Railway Station Building, Navi Mumbai

In the result, appeal of the assessee is allowed

ITA 712/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 Jun 2024AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(1)Section 143(1)(a)Section 2Section 4Section 80Section 80ISection 80PSection 80P(2)(d)

Shubham Nagri Sahakari Patsanstha Maryadit, Mumbai vs. Income Tax Officer, Ward 41(2)(5), Mumbai

In the result, appeal of the assessee is allowed

ITA 1065/MUM/2024[2013-14]Status: DisposedITAT Mumbai28 Jun 2024AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(3)Section 2Section 263Section 4Section 80Section 80PSection 80P(2)(d)

Veer Jijamata Co Op Credit Society Limited, Mumbai vs. Commisioner of Income Tax(Appeals), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4216/MUM/2023[AY 20-21]Status: DisposedITAT Mumbai28 Jun 2024

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhriveer Jijamata Co Op. Credit Vs. Cit(A) Ward 20(3)(1), Society Ltd. Piramal Chamber, 1/10 Ameher Market Bldg., Mumbai-4000012 B A Ambedkar Road, V. J. B. Udyan S. O., Mumbai-400027 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaav5873D Appellant .. Respondent

For Appellant: Mr. Vanesh Kr. NadarFor Respondent: Shri Himanshu Kumar
Section 143(1)Section 250Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Hariyaali Urban Co-Op Credit Society Ltd, Shahada vs. ITO, Ward 1, Dhule

ITA 862/PUN/2024[2017-18]Status: DisposedITAT Pune27 Jun 2024AY 2017-18

Bench: Ms. Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.862/Pun/2024 िनधा"रण वष" / Assessment Year : 2017-18 Hariyaali Urban Co-Op V The Income Tax Officer, Credit Society Ltd., S Ward-1, Dhule. Plot No.9, Krishna Kunj Colony, Near Vrundavan Nagar, Shahada, Maharashtra – 425409. Pan: Aaaah2547J Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Ganesh Budruk – Dr Date Of Hearing 25/06/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], U/Sec.250 Of The Act Dated 31.03.2024.The Assessee Has Raised Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Confirming The Disallowance Of Deduction U/S 80P(2)(A)(Ia) Of Rs.30,81,067 Made By The A.O In Respect Of Interest Earned On Deposits Made With The Nationalized Bank Without Appreciating That The Said Disallowance Was Not Justified In Law & On Facts. Hariyaali Urban Co-Op Credit Society Ltd., Shahada [A]

Section 143(3)Section 250Section 80PSection 80P(2)Section 80P(2)(a)

Income-Tax Officer, Ward - 3, Satara vs. M/S. Shri Bhairavnath Multi State Co-Operative Credit Society Ltd, Satara

In the result, the appeal filed by the Revenue is dismissed

ITA 2484/PUN/2017[2014-15]Status: DisposedITAT Pune27 Jun 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.2484/Pun/2017 "नधा"रण वष" /Assessment Year : 2014-15 Ito, Ward-3, Vs. M/S. Shri Bhairavnath Multistate Satara Cooperative Credit Society Ltd., 48, Laxminagar, Deccan Chowk, Phaltan, Tal. Phaltan, Dist. Satara-415523 Maharashtra Pan : Aaeas8344J Appellant Respondent

For Respondent: Shri Ramnath P. Murkunde
Section 143(3)Section 80Section 80PSection 80P(2)(a)

Shiva Vividhoddesha Sahakara Sangha Niyamita, Malebennur vs. Income Tax Officer Ward 2(1), Shree Towers, Hadadi Main Road, Davanagere

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

ITA 950/BANG/2024[2016-17]Status: DisposedITAT Bangalore27 Jun 2024AY 2016-17

Bench: Smt. Beena Pillaiassessment Year : 2016-17

For Appellant: Shri Aangira S Joshi, CA
Section 80P(2)Section 80P(2)(a)Section 80P(4)

Hassan Co-Operative Society Limited, Hassan vs. Income Tax Officer, Ward-1, Hassan

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

ITA 909/BANG/2024[2017-18]Status: DisposedITAT Bangalore27 Jun 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Hassan Co-Operative Society Ltd. The Income Tax Officer #1, Society Road Ward -1 Gandhi Bazar Vs. Aayakar Bhavan Hassan 573201 2Nd Stage, Belur Road Pan – Aaaah7251F Hassan 573201 (Appellant) (Respondent) Assessee By: Shri Tarun Kothari, Advocate Revenue By: Shri Ganesh R. Gale, Standing Counsel Date Of Hearing: 20.06.2024 Date Of Pronouncement: 27.06.2024 O R D E R Per: Soundararajan K., J.M. This Appeal Is Filed By The Assessee Challenging The Order Of The Commissioner Of Income Tax (Appeals), Kanpur (Cit(A))Dated 28.02.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (The Act) In Respect Of Assessment Year (Ay) 2017-18. 2. The Assessee Is A Co-Operative Society Registered Under The Provisions Of The Karnataka Co-Operative Societies Act & It Declared An Income Of Rs.9,98,941/- & Claimed Exemption Under Chapter Via Of The Act. The Assessing Officer (Ao) Had Disallowed A Portion Of The Claim On The Ground That The Same Are Not From The Investments Made With Any Other Co-Operative Societies & Therefore Not Eligible For Deduction Under Section 80P(2)(D) Of The Act. The Assessee Filed An Appeal Before The Cit(A) & Contended That The Income Earned By The Assessee Is Eligible For Deduction Under Section 2 Hassan Co-Operative Society Ltd. 80P(2)(A)(I) Of The Act Since The Assessee Had Invested The Surplus Funds By Way Of Temporary Deposit In Various Co-Operative Societies. The Cit(A) Decided The Appeal Ex-Parte & Dismissed The Same Since The Assessee Had Not Appeared Before Him In Spite Of Granting Five Occasions As Below: -

For Appellant: Shri Tarun Kothari, AdvocateFor Respondent: Shri Ganesh R. Gale, Standing Counsel
Section 2Section 250Section 57Section 80P(2)(d)Section 80P(2)(i)

Samrudh Vividoddesha Souharda Sahakari Niyamita, Shivamogga vs. Income-Tax Officer, Ward-5, Shivamogga

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

ITA 1085/BANG/2024[2017-18]Status: DisposedITAT Bangalore27 Jun 2024AY 2017-18

Bench: Smt. Beena Pillaiassessment Year : 2017-18 M/S. Samrudh Vividoddesha Souharda Sahakari Niyamita, The Income Tax 1St Floor, Belaguru Officer, Complex, Ward – 5, Durgigudi Main Road, Shivamogga. Shivamogga. Vs. Karnataka – 577 201. Pan: Aaals0413K Appellant Respondent

For Appellant: Shri Varun Bhat, CA
Section 142(1)Section 143(2)Section 2(19)Section 5(3)Section 80PSection 80P(2)(a)

Sri Siddeshwar Souharda Pattin Sahakari Niyamitha Vijayapura, Vijayapura vs. Income Tax Officer, Ward 1& Tps, Bijapur

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

ITA 1084/BANG/2024[2017-18]Status: DisposedITAT Bangalore27 Jun 2024AY 2017-18

Bench: Smt. Beena Pillaiassessment Year : 2017-18 M/S. Sri Siddeshwar Souharda Pattin Sahakari Niyamitha, The Income Tax Siddeshwara Road, Officer, Bijapur, Ward 1 & Tps, Vijayapura, Bijapur. Vs. Karnataka – 586 101. Pan: Aaabs1457M Appellant Respondent

For Appellant: Shri Varun Bhat, CA
Section 142(1)Section 143(2)Section 2(19)Section 5(3)Section 80PSection 80P(2)(a)Section 8o

Npc Employees Co Operative Credit Society Ltd, Mumbai vs. Income Tax Officer, Mumbai

In the result the solitary ground of appeal of the assessee is allowed

ITA 89/MUM/2024[2020-2021]Status: DisposedITAT Mumbai27 Jun 2024AY 2020-2021

Bench: Shri Prashant Maharishi (Am) I.T.A. No. 89/Mum/2024 (A.Y. 2020-21) Npc Employees Vs. Ito Ward 27(2)(1) Cooperative Credit Vashi Railway Society Limited Station, 4Th Floor Vikram Sarabhai Vashi, Navi Bhavan, South Wing Mumbai-400 703. 6Th Floor, Trombay Mumbai-400 094. Pan : Aaban0550E (Appellant) (Respondent) Assessee By Shri Sushant N. Alme Department By Shri R.R. Makwana Date Of Hearing 05.06.2024 Date Of Pronouncement 27.06.2024 O R D E R 1. This Appeal Is Filed By Npc Employees Cooperative Credit Society Ltd Mumbai (The Assessee/Appellant) For Assessment Year 2020 – 2021 Against The Appellate Order Passed By The National Faceless Appeal Centre (Nfac), Delhi (The Learned Cit – A) Dated 29/11/2023 Wherein The Appeal Filed By The Assessee Against The Assessment Order Passed By The Faceless Appeal Centre On 19/9/2022 Under Section 143 (3) Of The Income Tax Act, 1961 Was Dismissed. 2. The Only Dispute In This Appeal Is That Assessee Has Invested Surplus Amount In Fixed Deposits With State Bank Of India & Earned Interest Of ₹ 1,176,084/–. The Assessee Claimed Deduction Under Section 80 (P) (2) Of The Act Which Was Denied To The Assessee & Is Contested In This Appeal. 3. The Brief Facts Of The Case Shows That Assessee Is A Co-Operative Society Registered Under The Maharashtra State Cooperative Societies Act, 1961 Page 1 Of 6

Section 143Section 144Section 80

Cidco Employees Co-Op. Credit Society, Mumbai vs. ITO, Ward-28(1)(3), Mumbai

In the result, Tax Appeals are dismissed

ITA 600/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Jun 2024AY 2012-13

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2012-13 M/S. Cidco Employees Ward 28(1)(3), 3Rd Floor, Co. Op. Credit Society Ground Floor, Tower No. 6, Vs. Cidco Bhavan, Vashi Railway Station, Cbd- Belapur, Commercial Complex, Navi Mumbai- 400614. Mumbai- 400703. Pan: Aaaac2230N (Appellant) (Respondent) Present For : Assessee By : Shri Bhupendra Shah, A.R. Revenue By : Shri R. R. Makwana- Sr. D.R.

For Appellant: Shri Bhupendra Shah, A.RFor Respondent: Shri R. R. Makwana- SR. D.R
Section 143(1)Section 143(3)Section 148Section 2(24)(viia)Section 234BSection 250Section 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Saurashtra Jain Mutually Aided Co-Operative Society, Hyderabad vs. Income Tax Officer, Ward- 5(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 609/HYD/2024[2017-2018]Status: DisposedITAT Hyderabad26 Jun 2024AY 2017-2018

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No.609/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2017-18) The Saurashtra Jain Vs. Income Tax Officer Mutually Aided Ward 5(2) Cooperative Credit Society Hyderabad Ltd, Hyderabad Pan:Aayfs9752K (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Adv. Syed Jameeluddin रधजस् व द्वधरध/Revenue By:: Smt. P. Sumitha, Dr सुिवधई की तधरीख/Date Of Hearing: 26/06/2024 घोर्णध की तधरीख/Pronouncement: 26/06/2024 आदेश/Order

For Appellant: Adv. Syed JameeluddinFor Respondent: : Smt. P. Sumitha, DR
Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

Deputy Commissioner of Income Tax, Circle 1(1) and Tps, Hubballi, C R Building, Navanagar vs. Sirsi Taluka Agricultural Produce Marketing Co-Operative Society, Sirsi

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

ITA 949/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Jun 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Year: 2018-19

For Appellant: NONEFor Respondent: Ms. Neha Sahay, D.R
Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Alankar Primary Agricultural Credit Co Operative Society, Alankar vs. Income Tax Officer, Ward-1, Puttur

ITA 814/BANG/2024[2020-21]Status: DisposedITAT Bangalore26 Jun 2024AY 2020-21

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2020-21

For Appellant: Shri Srikrishna Kantilia, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 250Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Durga Co Op Credit Society Limited, Mumbai vs. Income Tax Officer, National Faceless Assessment Centre, Mumbai

In the result, appeal of the assessee is allowed

ITA 520/MUM/2024[2017-18]Status: HeardITAT Mumbai26 Jun 2024AY 2017-18

Bench: Shri Narender Kumar Choudhry, Judicialmember & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: NoneFor Respondent: Smt. Mahita Nair, Sr. DR
Section 270ASection 80P(2)(a)

Sarvodaya Credit Co Op Society Ltd Barkur, Udupi vs. Income-Tax Officer, Ward-1, Udupi

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

ITA 746/BANG/2024[2017-18]Status: DisposedITAT Bangalore25 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavsarvodaya Credit Co-Op. The Income Tax Officer Society Ltd. Ward -2, Udupi Car Street, Barkur Vs. Udupi 576210 Pan – Aaeas9576Q (Appellant) (Respondent) Assessee By: Smt. Sheetal Borkar, Advocate Revenue By: Ms. Neha Sahay, Jcit-Dr Date Of Hearing: 25.06.2024 Date Of Pronouncement: 25.06.2024 O R D E R Per: Prakash Chand Yadav, J.M. This Appeal Filed By The Assessee Challenges The Din & Order No. Itba/Nfac/S/2003-24/1061360577(1) Of The National Faceless Appeal Centre, Delhi (Cit(A)) Dated 22.02.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (The Act) In Respect Of Assessment Year (Ay) 2017-18. 2. The Brief Facts Of The Case Are That The Assessee Society Filed Its Return Of Income(Roi) On 06.11.2017 Declaring Gross Total Income Of Rs.18,34,325/- & Net Income As Nil. Roi Filed By Assessee Was Selected For Scrutiny, After Issuing Statutory Notices. During The Course Of Assessment Proceedings The Ld. Assessing Officer (Ao) Treated Certain Income Of The Assessee As Income From Other Sources(Ios) & Without Giving The Benefit Of The Expenses Attributable Ios Assessed The Entire Income Under The Head ‘Income From Other Sources’. The Ao Further Added Rs. 1,90,000/- On Account Of The Provisions Made By Assessee With 2 Sarvodaya Credit Co-Op. Society Ltd. Respect To Employee’S Retirement Fund & Provision With Respect To Nps Fund Amounting To Rs.27,57,696/-.

For Appellant: Smt. Sheetal Borkar, AdvocateFor Respondent: Ms. Neha Sahay, JCIT-DR
Section 250Section 57Section 80PSection 80P(2)(a)

Kome Koravadi Vividodeesha Sahakari Sangha Niyamitha, Udupi vs. Income Tax Officer, Ward-2, Udupi

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

ITA 982/BANG/2024[2017-18]Status: DisposedITAT Bangalore24 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Years : 2017-18

For Appellant: Shri Akshay K.S, C,AFor Respondent: Shri Ganesh R Gale, Standing Counsel for the Department, CIT (DR)
Section 143(2)Section 80P(2)(a)

Sri Lakshmi Multipurpose Cooperative Society Ltd, Udupi vs. ITO Ward - 1 and Tps, Udupi

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

ITA 935/BANG/2024[2016-17]Status: DisposedITAT Bangalore24 Jun 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Years : 2016-17 Sri Lakshmi Multipurpose Co-Operative Vs. The Income Tax Officer, Society Ltd., Ward – 1&Tps, Udupi. Floor-1, Srihari Tower, Kanakadasa Road, Udupi-576 101. Pan – Aakcs 4571 M Appellant Respondent Assessee By : Shri Ravindra Poojary, Advocate Revenue By : Shri Ganesh R Gale, Standing Counsel For Department Date Of Hearing : 20.06.2024 Date Of Pronouncement : 24 .06.2024 O R D E R Per Shri Prakash Chand Yadavinstant Appeal Of The Assessee Is Arising From The Order Passed By The Nfac, Delhi Dated 22/03/2024 In Din No. Itba/Nfac/S/ 250/2023- 24/1063170077(1) For The Assessment Year 2016-17. 2. Assessee A Cooperative Society, Could Not File Its Return Of Income For The Impugned Assessment Year. Thereafter, On The Basis Of An Information, Revealing That Assessee Has Deposited An Amount Of Rs.4,24,10,051, Ao Issued Notice U/S 148A To The Assessee. The Ao, Page 2 Of 4 While Framing The Assessment, Observed That The Assessee Is Not Qualified For Deduction U/S 80P(2)(A)(I) Of The Act, Relying Upon The Judgment Of Hon’Ble Apex Court In The Case Of Citizen Co-Operative Society Reported In 397 The Ao Framed The Assessment & Made An Addition Of Rs.48,53,282/-.

For Appellant: Shri Ravindra Poojary, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Department
Section 148Section 148ASection 149Section 149(1)(b)Section 80P(2)(a)