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    <title>2020 (12) TMI 179 - ITAT MUMBAI</title>
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    <description>A co-operative entity confined by its bye-laws to accepting deposits from members and providing credit facilities to members only was treated as a co-operative credit society, not a co-operative bank. The statutory definition of a co-operative bank under the Banking Regulation Act requires banking business involving dealings with the public, and the entity&#039;s lack of transactions with non-members or the general public meant it did not satisfy that character. A prior statement made in penalty proceedings could not alter the legal status derived from the governing documents and statutory framework. It was therefore entitled to deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961, and section 80P(4) did not apply.</description>
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