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    <title>2018 (3) TMI 1793 - ITAT CHENNAI</title>
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    <description>Primary agricultural co-operative credit societies were held not entitled to deduction under section 80P(2)(a)(i) for income from lending to associate members who had no voting rights, no dividend entitlement and no role in management, because they were admitted only to avail loans. The Tribunal treated the arrangement as lacking mutuality, since the persons contributing to surplus were not the same as those participating in it. It also followed Supreme Court guidance that a society carrying on finance-like activity with nominal members may fail the requirement of providing credit facilities to members for section 80P(2)(a)(i), and that failure is not confined to section 80P(4).</description>
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      <description>Primary agricultural co-operative credit societies were held not entitled to deduction under section 80P(2)(a)(i) for income from lending to associate members who had no voting rights, no dividend entitlement and no role in management, because they were admitted only to avail loans. The Tribunal treated the arrangement as lacking mutuality, since the persons contributing to surplus were not the same as those participating in it. It also followed Supreme Court guidance that a society carrying on finance-like activity with nominal members may fail the requirement of providing credit facilities to members for section 80P(2)(a)(i), and that failure is not confined to section 80P(4).</description>
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