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    <title>2024 (1) TMI 765 - ITAT COCHIN</title>
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    <description>A co-operative society carrying on banking activity was held not to be excluded from deduction under section 80P merely because it accepted deposits and functioned like a bank, since it was not shown to satisfy the statutory definition of a co-operative bank under section 80P(4). The provision was construed strictly and confined to its text, leaving section 80P(2)(a)(i) available for eligible co-operative banking income. Interest income in Sivapuram Service Co-operative Bank Ltd. was also allowed under section 80P(2)(d) to the extent it arose from investment with a co-operative bank and was not otherwise covered as banking income.</description>
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      <link>https://www.taxtmi.com/caselaws?id=448366</link>
      <description>A co-operative society carrying on banking activity was held not to be excluded from deduction under section 80P merely because it accepted deposits and functioned like a bank, since it was not shown to satisfy the statutory definition of a co-operative bank under section 80P(4). The provision was construed strictly and confined to its text, leaving section 80P(2)(a)(i) available for eligible co-operative banking income. Interest income in Sivapuram Service Co-operative Bank Ltd. was also allowed under section 80P(2)(d) to the extent it arose from investment with a co-operative bank and was not otherwise covered as banking income.</description>
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