Section 80P deduction for a co-operative credit society upheld where earlier years on identical facts were already accepted.

A co-operative credit society remained eligible for deduction under section 80P(2)(a)(i) where its claim had already been accepted in earlier assessment years on identical facts. The Tribunal followed its own coordinate bench rulings in the assessee's case and found no material distinction for the relevant year. Section 80P(4) did not operate to deny the deduction on these facts. The decision reiterates that, absent any change in facts or law, consistent earlier findings in the same assessee's case should ordinarily be followed.

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Issues: Whether the assessee, a co-operative credit society, was entitled to deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961, and whether section 80P(4) applied so as to deny the claim.

Analysis: The Tribunal noted that the dispute was recurring and that the issue had already been decided in the assessee's favour in earlier assessment years. The Commissioner (Appeals) had followed the Tribunal's earlier orders in the assessee's own case, and no material distinction in facts for the relevant year was shown. Following the coordinate bench decisions for the prior assessment years, the Tribunal found no reason to take a different view.

Conclusion: The assessee was entitled to deduction under section 80P(2)(a)(i), and section 80P(4) did not warrant denial of the claim in the facts of the case.

Ratio Decidendi: Where the assessee's eligibility for deduction under section 80P(2)(a)(i) has been consistently accepted in earlier years on identical facts, the coordinate bench decision should ordinarily be followed in the absence of any material change in facts or law.

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