Section 80P deduction is limited to income attributable to qualifying co-operative activities, not entire gross receipts.

Section 80P deduction under section 80P(1) read with section 80P(2)(a) is confined to income attributable to the specified co-operative society activities, not the entire gross receipts from those activities. The expression "gross total income" is read with section 80B(5), so the deductible amount is the profits and gains computed under the Act before Chapter VI-A deductions. Section 80AB is treated as clarificatory and consistent with that construction even for earlier assessment years. On that basis, only the income attributable to the qualifying activities is deductible, and the gross amount claimed is not fully allowable.

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Issues: Whether, for deduction under section 80P(1) read with section 80P(2)(a), the assessee co-operative society was entitled to deduct the entire gross receipts from the specified activities or only the portion representing income attributable to those activities.

Analysis: Section 80P allows deduction from the gross total income only of the sums specified in sub-section (2), and the expression "gross total income" takes its meaning from section 80B(5). The phrase "the whole of the amount of profits and gains of business attributable to any one or more of such activities" must therefore be read as the income computed in accordance with the Act before Chapter VI-A deductions, not as the gross receipts themselves. Section 80AB, though inserted later, was treated as clarificatory and as reflecting the correct meaning of the provision even for the earlier assessment year. The deduction is thus confined to the income attributable to the specified activities and not to the entire gross amount claimed.

Conclusion: The assessee was not entitled to deduction of the entire gross amount; only the income attributable to the specified activities was deductible, and the question was answered in favour of the Revenue.

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