Appeal granted for loans' agricultural use review under section 80P - fresh examination ordered.

The Tribunal allowed the appeal for statistical purposes, directing a fresh examination by the Assessing Officer to determine if the loans were for agricultural purposes as per the Full Bench's directives. The case was remanded for a comprehensive review and decision in accordance with the law, emphasizing the necessity of scrutinizing loan disbursements to establish the society's eligibility for deductions under section 80P of the I.T. Act.

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Issues:
- Whether the CIT(A) was justified in confirming the Assessing Officer's order denying the claim of deduction u/s 80P(2)(a)(i) of the I.T. Act for the assessment year 2014-2015.

Analysis:
1. Background and Facts: The appellant, a cooperative society, filed a return for the assessment year 2014-2015 claiming a deduction u/s 80P of the I.T. Act. The Assessing Officer disallowed the deduction, considering the appellant's activities as banking, leading to the denial of the claim.

2. CIT(A) Decision: The CIT(A) upheld the Assessing Officer's decision based on the finding that the appellant's agricultural credit activities were minimal, and the society couldn't be classified as a primary agricultural credit society. This decision was influenced by the judgment of the Full Bench of the jurisdictional High Court.

3. Tribunal's Analysis: The Tribunal referred to conflicting judgments by the High Court. While a previous judgment favored granting deductions based on the classification by the Registrar of Co-operative Societies, a later Full Bench decision emphasized the need for the Assessing Officer to scrutinize the actual activities of the society. The Tribunal noted that the Assessing Officer's examination of loan disbursements was superficial and lacked a detailed analysis of whether loans were for agricultural purposes.

4. Fresh Examination Ordered: Considering the Full Bench's ruling, the Tribunal directed the Assessing Officer to conduct a thorough review of each loan disbursement to determine if they were for agricultural or non-agricultural purposes. The Tribunal emphasized the need for a detailed assessment following the guidelines set by the High Court's Full Bench decision in a similar case.

5. Decision and Conclusion: The Tribunal allowed the appeal for statistical purposes, instructing a fresh examination by the Assessing Officer in line with the Full Bench's directives. The case was restored to the Assessing Officer for a comprehensive review and a decision in accordance with the law.

In conclusion, the Tribunal's decision highlighted the importance of a detailed examination of loan disbursements to ascertain the nature of the society's activities and eligibility for deductions under section 80P of the I.T. Act.

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