Primary Agricultural Credit Society classification governs section 80P deduction and bars contrary denial under section 80P(4).

A co-operative society classified by the competent statutory authority as a Primary Agricultural Credit Society was treated as entitled to deduction under section 80P(2)(a)(i) of the Income-tax Act. That statutory classification governed the claim, and the income-tax authorities could not make a contrary factual inquiry to deny the benefit. Section 80P(4) was therefore held inapplicable to defeat the deduction where the society's status had already been certified under the Kerala Co-operative Societies Act, 1969. The decision distinguished an earlier Revenue-reliance precedent as arising in a different context and not displacing the binding effect of the statutory classification.

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Issues: Whether the assessee, being classified by the competent authority as a Primary Agricultural Credit Society, was entitled to deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961, and whether section 80P(4) could be invoked to deny the claim.

Analysis: The assessee had produced a certificate issued under the Kerala Co-operative Societies Act, 1969 classifying it as a Primary Agricultural Credit Society. The earlier jurisdictional view relied upon by the Revenue was distinguished on the ground that it dealt with a different context and did not displace the binding effect of the statutory classification. On the basis of the certificate and the jurisdictional High Court ruling relied upon by the first appellate authority, the nature of the assessee as a Primary Agricultural Credit Society was accepted, and the income-tax authorities were held not entitled to undertake a further probe inconsistent with that classification for the purpose of denying the deduction.

Conclusion: Section 80P(4) could not be invoked to deny deduction under section 80P(2)(a)(i), and the assessee was held entitled to the benefit claimed.

Ratio Decidendi: Where a co-operative society stands classified by the competent statutory authority as a Primary Agricultural Credit Society, that classification governs entitlement to deduction under section 80P(2)(a)(i) and excludes denial under section 80P(4) on a contrary factual inquiry by the income-tax authorities.

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