Deduction under section 80P(2)(d) upheld for cooperative society on interest from cooperative bank, following favorable precedent.

Cooperative society interest from a cooperative bank is held to fall within the deduction prescribed by section 80P(2)(d); the conclusion rests on applying the statutory framework for cooperative society deductions and following the Supreme Court ratio in Mavilayi Services Cooperative Bank Limited, while distinguishing earlier Totgar's Sale authority. Coordinate Tribunal benches that adopted Mavilayi's interpretation were followed, and on that precedent the appellant's claim for deduction in respect of interest income from the cooperative bank is allowed, resulting in allowance of the appeal in favour of the assessee.

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Issues: Whether the appellant cooperative society is entitled to deduction for interest income from a cooperative bank under section 80P(2)(d) of the Income-tax Act, 1961.

Analysis: The issue concerns entitlement to deduction under section 80P(2)(d) and competing precedents. The decision applies the legal framework governing statutory deductions available to cooperative societies and examines relevant authorities, including the Supreme Court decision in Mavilayi Services Cooperative Bank Limited and the earlier Totgar's Sale Cooperative Society decision. Coordinate benches of the Tribunal have distinguished Totgar's Sale on facts and law and have followed Mavilayi Services Cooperative Bank Limited to hold that similar cooperative societies claiming interest income deduction fall within the scope of section 80P(2)(d). Having regard to those authorities and the ratio applied by coordinate benches, the appellant society's claim for deduction in respect of interest income from the cooperative bank is held to be covered by the precedent favouring deduction.

Conclusion: The appellant cooperative society is entitled to deduction under section 80P(2)(d) of the Income-tax Act, 1961; the appeal is allowed in favour of the assessee.

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