Co-operative credit society deduction under section 80P remains available where the entity is not a co-operative bank.

A co-operative credit society that accepts deposits and lends only to its members remains eligible for deduction under section 80P, because the exclusion in section 80P(4) applies to co-operative banks and not to a credit society that is not itself a co-operative bank. The related amendment to section 2(24)(viia) did not alter that position on the facts considered. The conclusion was reinforced by the coordinate bench view in the assessee's earlier year, and the Revenue's challenge failed.

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Issues: Whether a co-operative credit society engaged in accepting deposits and lending only to its members is entitled to deduction under section 80P of the Income-tax Act, 1961 despite the insertion of section 80P(4) and the related amendment to section 2(24)(viia).

Analysis: The claim for deduction was examined in the light of the statutory scheme governing co-operative banks and co-operative credit societies. The decisive consideration was that the assessee was a co-operative credit society and not a co-operative bank. On that basis, the exclusion in section 80P(4) was held inapplicable. The conclusion was supported by the coordinate bench decision in the assessee's own case for an earlier assessment year and by the view that the exclusion provision does not extend to credit societies which are not co-operative banks.

Conclusion: The assessee was entitled to deduction under section 80P, and the Revenue's challenge failed.

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