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    <title>2022 (9) TMI 346 - ITAT PANAJI</title>
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    <description>Section 80P(2)(a)(i) remains available to a primary agricultural credit co-operative society where the entity provides credit facilities only to its members and is not shown to be a co-operative bank with an RBI banking licence. The exclusion in section 80P(4) applies to co-operative banks carrying on banking business, not to every co-operative society engaged in member credit transactions. Associate or nominal members treated as members under the governing co-operative law do not, by themselves, defeat the deduction. The Revenue&#039;s reliance on contrary precedent was distinguished on the ground that it involved dealings with third parties and banking-like features inconsistent with a genuine co-operative society.</description>
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      <description>Section 80P(2)(a)(i) remains available to a primary agricultural credit co-operative society where the entity provides credit facilities only to its members and is not shown to be a co-operative bank with an RBI banking licence. The exclusion in section 80P(4) applies to co-operative banks carrying on banking business, not to every co-operative society engaged in member credit transactions. Associate or nominal members treated as members under the governing co-operative law do not, by themselves, defeat the deduction. The Revenue&#039;s reliance on contrary precedent was distinguished on the ground that it involved dealings with third parties and banking-like features inconsistent with a genuine co-operative society.</description>
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