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    <title>2014 (10) TMI 390 - ITAT COCHIN</title>
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    <description>A co-operative society claiming status as a Primary Agricultural Credit Society sought deduction under section 80P(2)(a)(i), but the Tribunal treated it as a co-operative bank for section 80P(4) purposes because its activities were in substance banking activity, with lending confined to members and no banking licence. The Tribunal followed its earlier decision on identical facts and held that the exclusion in section 80P(4) applied, so the deduction claim failed. The alternative plea based on mutuality was also rejected because lending to members and profit distribution did not satisfy the mutuality requirements in the context of the society&#039;s operations.</description>
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      <title>2014 (10) TMI 390 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=252256</link>
      <description>A co-operative society claiming status as a Primary Agricultural Credit Society sought deduction under section 80P(2)(a)(i), but the Tribunal treated it as a co-operative bank for section 80P(4) purposes because its activities were in substance banking activity, with lending confined to members and no banking licence. The Tribunal followed its earlier decision on identical facts and held that the exclusion in section 80P(4) applied, so the deduction claim failed. The alternative plea based on mutuality was also rejected because lending to members and profit distribution did not satisfy the mutuality requirements in the context of the society&#039;s operations.</description>
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