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    <title>2026 (5) TMI 46 - ITAT BANGALORE</title>
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    <description>A credit co-operative society registered under the Karnataka Souharda Sahakari Act, 1997 was treated as a co-operative society within section 2(19) of the Income-tax Act and was held entitled to deduction under section 80P(2)(a)(i) on income attributable to providing credit facilities to members, including regular or nominal members. The record did not establish dealings with non-members, so the revenue&#039;s basis for denying the deduction on that ground failed. A disallowance of tax-related expenditure did not defeat the deduction because it only affected the quantum of eligible business income, and the alternative denial under section 80P(2)(d) also failed since the assessee had not claimed the income under that provision.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790844</link>
      <description>A credit co-operative society registered under the Karnataka Souharda Sahakari Act, 1997 was treated as a co-operative society within section 2(19) of the Income-tax Act and was held entitled to deduction under section 80P(2)(a)(i) on income attributable to providing credit facilities to members, including regular or nominal members. The record did not establish dealings with non-members, so the revenue&#039;s basis for denying the deduction on that ground failed. A disallowance of tax-related expenditure did not defeat the deduction because it only affected the quantum of eligible business income, and the alternative denial under section 80P(2)(d) also failed since the assessee had not claimed the income under that provision.</description>
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