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    <title>2023 (5) TMI 1238 - ITAT MUMBAI</title>
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    <description>A credit co-operative society that provides credit facilities only to its members is eligible for deduction under section 80P(2)(a)(i) of the Income-tax Act and is not excluded by section 80P(4) merely because it lends to members. The governing principle is that lending confined to members does not amount to banking activity under section 5(b) of the Banking Regulation Act, 1949, so such a society is not treated as a co-operative bank. Prior Tribunal, jurisdictional High Court, and Supreme Court authority were noted as supporting this distinction, leaving the deduction available to member-only credit societies.</description>
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      <title>2023 (5) TMI 1238 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=308898</link>
      <description>A credit co-operative society that provides credit facilities only to its members is eligible for deduction under section 80P(2)(a)(i) of the Income-tax Act and is not excluded by section 80P(4) merely because it lends to members. The governing principle is that lending confined to members does not amount to banking activity under section 5(b) of the Banking Regulation Act, 1949, so such a society is not treated as a co-operative bank. Prior Tribunal, jurisdictional High Court, and Supreme Court authority were noted as supporting this distinction, leaving the deduction available to member-only credit societies.</description>
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