Section 80P deduction for co-operative society upheld under binding precedent, with disallowance set aside.

A co-operative society's entitlement to deduction under Section 80P was examined in light of the exclusion in Section 80P(4). The Tribunal applied the Supreme Court ruling in Mavilayi Service Cooperative Bank Ltd. v. CIT as binding precedent and held that the deduction could not be denied on the basis adopted by the Assessing Officer and the first appellate authority. The assessee was accordingly held entitled to the Section 80P deduction, and the disallowance was set aside.

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Issues: Whether the assessee, a co-operative society, was entitled to deduction under Section 80P of the Income-tax Act, 1961 despite the exclusion in Section 80P(4).

Analysis: The Tribunal noted that the issue stood covered by the Supreme Court ruling in Mavilayi Service Cooperative Bank Ltd. v. CIT. Applying that binding precedent, the Tribunal held that the assessee's claim for deduction could not be denied on the basis adopted by the Assessing Officer and the first appellate authority.

Conclusion: The assessee was held entitled to the deduction under Section 80P, and the disallowance was set aside in its favour.

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