TaxTMI 
TaxTMI 
2024 (2) TMI 1040
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....rlinked or in fact interwoven and the facts and circumstances of other cases are identical except the difference in the amount disputed in other cases. The ld. DR did not raise any specific objection against taking that case as a lead case. Therefore, for the purpose of the present discussions, the case of ITA No. 247/Jodh/2023 is taken as a lead case. Based on the above arguments we have also seen that for these appeals grounds are similar, facts are similar, and arguments were similar and therefore, were heard together and are disposed by taking lead case facts, grounds, and arguments from the folder in ITA No. 247/Jodh/2023. 4. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in ITA No. 247/Jodh/2023 on the following grounds; "1. That on the facts and in the circumstances of the case the proceedings initiated for rectification u/s 154 of the IT Act by the learned AO is bad in law and bad on facts. 2. That the Appellate Authority was wrong in holding the initiation of proceedings u/s 154 of The IT Act as proper particularly when the deduction claimed by the appellant u/s 80 P(2) (d) was claimed in the original ret....
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....aimed u/s 80P (2)(d) of the IT Act. 6. Aggrieved from the order of Assessing Officer, the assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here in below: 7. I have carefully examined the submission of the appellant as reproduced in the preceding paragraph and the facts emanating from the A.O's order, wherein various disallowances and additions have been made. 7.1 In the Ground No.1, 5 & 6 of the appeal are general in nature not requiring any adjudication. Ground No.2 is on the issue relating to regarding the treatment of interest income earned by the appellant. The AO has disallowed the claim of exemption u/s.80P by the appellant in respect of interest income earned from banks. At the outset it may be mentioned that this issue has now been finally settled as has been discussed in the succeeding paragraphs of this order. 7.1.1 The issue to be decided is with regard to the interest income earned on account of investments made with Banks, whether it is entitled to deduction either u/s 80P(2)(d) or u/s 80P(2)(a)(i) of the I.T.Act. The Bangalore Bench of the Tribunal in the case of M/s. V....
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....essee for providing credit facilities to its members. The Assessee claimed that the said interest amount is attributable to the business of providing credit facilities by the assessee and forms part of profits and gains of business. The Hon'ble Karnataka High Court after considering SC judgment in case of Totgars(supra) held that since the word income is qualified by the expression "attributable" to the business of Banking is used in Sec. 80P(2)(a)(i) of the Act, it has to receive a wider meaning and should be interpreted as covering receipts from sources other than the actual conduct of business. The Court held a Cooperative Society which is carrying on the business of providing credit facilities to its members, earns profits and gains of business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains of the business of providing credit facilities to its members only. The society is not carrying on any separate business fo....
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....gard to deduction under Section 80P(2)(a)(i) of the Act and not under Section 80P(2)(d) of the Act. 10. However, the Hon'ble Karnataka High Court in the case of PRINCIPAL COMMISSIONER OF INCOME TAX AND ANOTHER vs. TOTAGARS CO- OPERATIVE SALE SOCIETY 395 ITR 0611 (Karn) took a different view and held that interest income earned on deposits whether with any other bank will be in the nature of income from other sources and not income from business and therefore the deduction u / s_{r} 80P(2)(d) of the Act cannot be allowed to the Assessee. The Hon'ble Court followed decision of Hon'ble Gujarat High Court in the case of SBI Vs. CIT 389 ITR 578(Guj.) in which the Hon'ble Gujarat High Court dissented from the view taken by the Hon'ble Karnataka High Court in the case of Tumkur Merchants case (supra) The Hon'ble Court had to deal with the following substantial question of law: "(I) Whether the assessee, Totagar Co-operative Sale Society, Sirsi, is entitled to 100% deduction under Section 80P(2)(d) of the Income Tax Act, 1961 (for short 'the Act') in respect of whole of its income by way of interest earned by it during the relevant Assessment Years from ....
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....to be excluded from the beneficial provisions of exemption or deduction under Section 80P of the Act. The purpose of bringing on the statute book sub-section (4) in Section 80P of the Act was to exclude the applicability of Section 80P of the Act altogether to any co-operative bank and to exclude the normal banking business Income from such exemption/deduction category. The words used in Section 80P(4) are significant. They are: "The provisions of this section shall not apply in operative bank other than a primary agricultural credit society". relation to any co The words "in relation to can include within its ambit and scope even the interest income earned by the respondent-assessee, a cooperative Society from a Co-operative Bank. This exclusion by Section 80P(4) of the Act even though without any amendment in Section 80P(2)(d) of the Act is sufficient to deny the claim of the respondent assessee for deduction under Section 80P(2)(d) of the Act. The only exception is that of a primary agricultural credit society. (Paragraph-14 of the judgment) 3. The amendment of Section 194A(3)(v) of the Act excluding the Cooperative Banks from the definition of "Co-operative Society" by Fina....
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....tinguishable and cannot be applied in the present appeals, in view of the binding precedent from the Hon'ble Supreme Court." (Paragraph 19 of the Judgment) 12 The Hon'ble Karnataka High Court in the aforesaid decision also placed reliance on a decision of the Hon'ble Gujarat High Court in the case of STATE BANK OF INDIA (SBI) vs. COMMISSIONER OF INCOME TAX 389 ITR 0578 (Guj) did not agree with the view taken by the Kamataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. (supra) that the decision of the Supreme Court in Totgars Co-operative Sale Society (supra) is restricted to the sale consideration received from marketing agricultural produce of its members which was retained in many cases and invested in short term deposit/security and that the said decision was confined to the facts of the said case and did not lay down any law. The Hon'ble Gujarat High Court held that in the case of Totgars Cooperative Sale Society (supra) decided by Hon'ble Supreme Court, the court was dealing with two kinds of ds of activities st interest income earned from the amount retained from the amount payable to the members from whom produce was bought and which ....
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....tion 80P(2)(d) of the Act specifically exempts interest earned from funds invested in cooperative societies. Therefore, to the extent of the interest earned from investments made by it with any co-operative society, a co-operative society is entitled to deduction of the whole of such income under section 80P(2)(d) of the Act. However, interest earned from investments made in any bank, not being a co- operative society, is not deductible under section 80P(2)(d) of the Act. 14. The CIT was therefore justified in exercising his powers of revision u/s.263 of the Act and directing the AO to tax interest income in question as it is neither of the nature specified in Sec. 80P(2)(a) (i) or 80P(2)(d) of the Act. 15. The argument of the le Lfor the see Assessee has been that the AO has applied his mind and allowed the deduction and therefore the jurisdiction u/s.263 of the Act cannot be exercised. On this argument, the learned DR pointed out that the jurisdiction u/s 263 of the Act was exercised by the CIT not for the reason that the AO failed to make proper enquiries before concluding the Assessment but on the ground that his decision was contrary to decision of Hon'ble Jurisdiction....
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....years wherein even the ld. CIT(A) has allowed the said claim earlier year and in some of the cases action u/s 154 of the Act has been done and any other years action of section 147 has been initiated and thereby in all these appeals challenging the same issue of deduction u/s. 80P(2)(d) of the Act. The issue is squarely covered by the various decisions of the Jodhpur Bench as well as Jaipur Benches of ITAT and therefore, the denial of exemption to the assessee u/s 80P(2)(d) of the Act is required to be allowed. In support of the grounds so raised in these appeal the ld. AR of the assessee has filed the following submission: Appellant is Co-Operative Society engaged in Consumer Co-Operative Store and registered under the Rajasthan Co-Operative Societies Act, 1953. * During the year certain interest was received from deposit with Co-Operative Bank, on which the deduction was originally allowed in 143(3) assessment under section 80P. In all earlier years also, such claim was always allowed. In A.Y. 2014-15 and 2015-16 where such disallowance was made was allowed in appeal by CIT(A) and no further appeal filed by the department in appeal on such issue. * On the same issue the pro....
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....Perusal of reasons to believe indicate that on verification of Annex. "F" of the Tax Audit Report and the notes thereto, it was found that the assessee had not quantified the amount of additional depreciation @10 per cent on the eligible assets purchased in the preceding year and had made passing remarks without substantiating its claim-Reopening the assessment has been based on the very annexure of the audit report which was available to the Revenue in the exercise that was carried out during the scrutiny assessment-Reason to believe therefore cannot be said to be based on any new of fresh tangible material and cannot therefore be used as a tool to reopen the assessment proceedings-Assessee has been claiming additional depreciation at the rate of 20 per cent on the eligible plant and machinery by virtue of the provisions of s. 32(1)(iia)- Assessment has been reopened beyond a period of four years and it is not a case where it can be said that the assessee has failed to disclose fully and truly all material facts necessary for his assessment-Thus during the course of original proceedings, the claim of the depreciation allowance as made by the AO was examined and after considering t....
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....he words " reason to believe" but also inserted the word " opinion" in s. 147 of the Act. However, on receipt of representations from the companies against omission of the words " reason to believe", Parliament reintroduced the said expression and deleted the word " opinion" on the ground that it would vest arbitrary powers in the AO. * DCIT vs. Cholamandalam Investment & Finance Co. Ltd. (2022) 36 NYPTTJ 319 (Chennai) Reassessment-Change of opinion-Absence of tangible material- Issue of adjustment of security premium by reduction of capital while computation under s. 115JB and on the other hand, the amount was taken in the Revenue account as transferred from securities premium account which was credited in the P&L a/c, so, there is no effect in the net profit already disclosed in tax audit report-During the assessment under s. 143(3), the AO never pointed out the issue as escapement of income-Reopening was made as per the report of the CAG. So, there is no tangible material to the AO for permission of reasonable believe for escapement of income-Further, there is no failure on the part of the assessee to disclose fully and truly all material facts necessary for this assessment-....
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.... income was received from the cooperative society. * Reliance is placed on decision of Hon'ble Madras High Court in the case of Thorapadi Urban Co-Op Credit Society Limited & Ors. Vs. ITO in WP 11172 of 2023 in order dated 10.10.2023 had quashed proceedings u/s 148 under exactly similar facts and circumstances involving deduction u/s 80P(2)(d) and held that such deduction is allowable and the relevant order of the Hon'ble Court is reproduced hereunder : "The issue involved in all these writ petitions are common and hence, they are taken up together, heard and disposed off through this common order. 2. The present writ petitioners challenged the impugned notices issued under Section 148 A(b) for reopening the assessment made u/s.148 of the Income Tax Act, 1961 (in short, 'the Act'). The central issue that arise in the present case is as to whether the petitioners are entitled for deduction under Section 80P(2)(d) of the Act. The petitioners submitted that they have made investments with the Cooperative Bank from which, they received interest and therefore they are entitled to claim deduction under section 80P(2)(d). However, the respondent in the impugned notices, has ....
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....In reply, the learned counsel for the petitioner submitted that the law laid down by the Hon'ble Supreme Court in the above said judgment is pertaining to the interpretation and the deduction which would be applicable under Section 80P(2)(a)(i), where it was held, the Co-operative Bank is eligible for deduction if any interest income is received from its own members by providing credit facilities. Therefore, even the said judgment is taken into consideration in the present case, the income was received by the Cooperative Society only and not from the Co-operative Bank, hence the petitioner is eligible for the deduction. 7. I have given due consideration for the submission made by the learned counsel appearing for the petitioner as well as the respondent. 8. The main issue is to decide in the present case is as to whether the petitioner Co-operative Society is entitled for a deduction for the interest income received from the Co-operative Bank? 9. It would be appropriate to extract hereunder the relevant portion of Section 80P(2)(d). "80 P. Deduction in respect of income of cooperative societies: (1) ...... ..... ..... (2) The sums referred to in sub-section (1) shal....
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....39;ble Supreme Court is not applicable for in the present case as the eligibility of deduction of interest has to be decided under Section 80P(2)(d) and not under Section 80P(2)(a)(i). The learned counsel has also relied upon other judgments which are not applicable for the present facts of the present case 12. At this juncture, it would be appropriate to refer a judgment passed by a Division Bench of this Court in "Commissioner of Income Tax Salem v. The Salem Agricultural Producers Co-operative Marketing Society Ltd" in Tax Case Appeal No.5 of 2015, wherein, apart from other substantial issues, the following issue has been framed for consideration, which reads as under: "Whether on the facts and in the circumstances of the case, the Tribunal was right in holding that the assessee is to be treated as primary agricultural society and is carrying on the business of banking or providing credit facilities to its members and is entitled for deduction under Section 80P(2)(a)(i) of the Income Tax Act, 1961 with respect to the interest received from Class B members who were involved in non-agricultural society?". While answering to the above, the Division Bench held that the respond....
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....est of the said investment related to Co-operative Society- Hence, assessee is eligible for deduction under s. 80P(2)(a)(i)-Principal CIT vs. Totgars Coop Sale Society (2017) 392 ITR 74 (Kar), Tumukur Merchants Souhard Credit Coop. Ltd. vs. ITO (2015) 55 taxmann.com 447 (Kar), CIT vs. Gulshan Mercantile Urban Co-operative Bank Ltd. (2013) 29 taxmann.com 8 (All), Kaliandas Udyog Bhavan Memises Co-operative Society Ltd. vs. ITO (ITA No. 6547/Mum/2017, dt. 25th April, 2018) and Tirupati Campus Ph. II Co- Op. Housing Society Maryadit vs. ITO (ITA No. 1429/Pune/2018, dt. 28th Feb., 2019) followed; Totgar Cooperative Sales Society Ltd. vs. ITO (2010) 229 CTR (SC) 209 : (2010) 35 DTR (SC) 25 : (2010) 188 Taxman 282 (SC) distinguished * ITO V/s The Totagars Co-operative Sale Society, ITA No 100069/2016. Reported in (2017) 392 ITR 74 (Kar) In the above case honorable Karnataka High Court has considered following facts before passing an order. a) "The word "Co-operative Society" are the words of a large extent, and denotes a genus, whereas the word "Co-operative Bank" is a word of limited extent, which merely demarcates and identifies a particular species of the genus Cooperative Societi....
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....being a benevolent provision must be read liberally and reasonably, and if there is ambiguity, in favour of the assessee- Further, s. 80P(4) is to be read as a proviso, which specifically excludes co-operative banks which are co-operative societies engaged in banking business i.e. engaged in lending money to members of the public, which have a licence in this behalf from the RBI-Therefore, once s. 80P(4) is not applicable to the facts of the case, all the assessees in the present case are entitled to the benefit of the deduction under s. 80P(2)(a)(i), notwithstanding that they may also be giving loans to their members which are not related to agriculture-'Nominal members' are 'members' as defined under the Kerala Co-operative Societies Act, 1969-Thus, loans given to such nominal members would qualify for the purpose of deduction under s. 80P(2)(a)(i). * Rena Sahakari Sakhar Karkhana Ltd V/s PCIT. In the above judgment it was held that while allowing deduction u/s 80P(2)(d) co-operative banks are considered as Co-operative Society as the word Co-operative society has wider meaning which also includes cooperative banks and it was further held that the amendment u/s 80P(4) has been ....
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.... Sahkari Sangh Ltd. (2005) 277 ITR 35 (All) followed. * Jansevak Co operative society ltd v/s ITO order dated 26.05.2023 reported in (2023) 37 NYPTTJ 739 (Mumbai). In this case the Hon'ble Tribunal has also explained about the decision of Karnataka High Court in the case of Principal CIT and Anr. vs. Totgar's Co-Operative Sale Society Ltd (2017) 292 ITR 74 (KAR) and various other cases wherefrom your honorably please observe that the decision of Hon'ble Supreme Court in the case of Totgar's co-operative sale society is not relevant for deduction allowable u/s 80 (P)(2) (d) of the I T Act. Deduction under s. 80P(2)(d)-Providing credit facilities to members- Applicability of s. 80P(4)-Assessee is a co-operative society, which is engaged in providing credit facilities to its members-Thus, if any income as referred to in sub-s. (2) to s. 80P is included in the gross total income of the assessee, the same shall be allowed as a deduction-It is pertinent to note that since the assessee is registered under the Maharashtra Co-operative Societies Act, 1960, it is required to invest or deposit its funds in one of the modes provided in s. 70 of the aforesaid Act, which includes investment ....
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....-operative bank other than a primary agricultural credit society or a primary co-operative society for agricultural land and rural development bank-In the present case, the assessee is a co-operative society whose primary object is to provide financial accommodation to its members who are other co-operative societies and not members of the public-Thus, the interest received by the assessee from Baroda Rajasthan Gramin Bank Ltd., which is a Regional Rural Bank and not a co-operative bank is not allowable as deduction under s. 80P(2)(d) as this entity is not a co-operative society-However, interest received by the assessee from Central Co-operative Bank is allowable as deduction under s. 80P(2)(d)-Kerala State Co-operative Agricultural & Rural Development Bank Ltd. (KSCARDB) vs. AO & Ors. (2023) 334 CTR (SC) 601 : (2023) 230 DTR (SC) 1 followed * Palm Court M Premises cooperative society Ltd V/s PCIT (2022) 145 Taxmann.com 415 (ITAT Mumbai) In this case the Honorable ITAT has taken support from the judicial pronouncement of honorable Karnataka High Court in the case of PCIT V/s Totagars cooperative sale society (2017) 392 ITR 74 (Karn.) which clearly states that interest derived by....
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....ies Ltd. vs. CIT (2009) 319 ITR 208 (SC) : (2009) 227 CTR (SC) 313 Rectification-Debatable issue or debatable-Issue of power subsidy granted by the Government-In each case, one has to examine the nature of subsidy and this exercise cannot be taken under s. 154-As the CIT has already in its order under s. 264 had taken the view that the subsidy in question was a capital receipt not taxable under the Act, therefore, he alter the judgment of the Supreme Court cannot charge his opinion taking view that subsidy in question was revenue receipt-hence Dy. CIT erred in passing order under s. 154 Held : The short point involved in these appeals is, whether there existed a " rectifiable mistake" enabling the Department to invoke s. 154 of the Act ? If one examines the scheme of the Income-tax Act, as it stood at the material time, one finds a clear dichotomy between s. 154 and s. 147 of the Act. Sec. 154 deals with rectification of mistake. Sec. 154(1), inter alia, states that, with a view to rectify any mistake apparent from the record, an Income-tax authority may amend any order passed by it under the provisions of the Act, whereas s. 147, inter alia, states that if the AO has reason to....
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....rs. (1989) 75 CTR (Ker) 115 : (1988) 174 ITR 579 (Ker), the facts were as follows : the assessee claimed interest on advance tax paid by it in excess but beyond the due dates. The Income-tax Officer disallowed the claim of the assessee. The Commissioner of Income-tax upheld the claim of the assessee. Following the decision of a learned single judge of the Kerala High Court in A. Sethumadhavan vs. CIT & Anr. (1980) 16 CTR (Ker) 376 : (1980) 122 ITR 587 (Ker), the Tribunal held that belated payments were not to be taken into account as advance tax for the purpose of s. 214 of the Income-tax Act, and, therefore, interest was not admissible for such belated payments. However, subsequently, a Division Bench of the same High Court in Santha S. Shenoy & Ors. vs. Union of India & Ors. (1982) 29 CTR (Ker) 127 : (1982) 135 ITR 39 (Ker) reversed the decision of the learned single judge in A. Sethumadhavan (supra) and held that payment of tax made within the financial year, though not within specified dates, should be treated as advance tax and, consequently, the assessee was entitled to interest on excess tax paid. The assessee filed an application under s. 154 of the Act for rectification of....
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....e heard learned counsel. We do not agree that the question raises a pure question of fact ; to that extent, the High Court was in error. But it was not in error in coming to the conclusion that there was no occasion for rectification. Under the provisions of s. 154 there has to be a mistake apparent from the record. In other words, a look at the record must show that there has been an error and that error may be rectified. Learned counsel for the Revenue has not been able to satisfy us that it shows any apparent error upon the record. Reference to documents outside the record and the law is impermissible when applying the provisions of s. 154. * DINOSAUR STEELS LTD. vs. JCIT (2012) 254 CTR (SC) 640 Rectification-Debatable issue-Deduction under s. 80-IA before setting off earlier years' losses-Provisions of Chapter VI-A, particularly those dealing with quantification of deductions have been amended several times-Even s. 80-IA was preceded by ss. 80HH and 80-I which resulted in plethora of case law-Thus, it cannot be said that there was a patent mistake in the assessment order allowing deduction under s. 80-IA before setting off the earlier year's losses- Moreover, assessee has....
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....issioner of IT in case of BPTD Ltd. Source (2023) 37 NYPTTJ 1465( Del) * Devi Construction vs. DCIT Pune Bench (2020) 207 TTJ (Pune) 130 Sec. 36(1)(iii) provides for deduction of 'the amount of the interest paid in respect of capital borrowed for the purposes of business or profession'. It is thus overt that so long as the business purpose' test is satisfied, there can be no disallowance of interest. 'Business purpose' does not encompass only the revenue field, but also covers the capital sphere. If a loan is taken and some capital asset, is purchased, interest on such a loan is also deductible in the same way as a loan is taken for satisfying working capital requirements. It is for the raison d'etre that as such loan for purchasing capital asset satisfies the requirement of business purpose. * The appellant submits that the initiation of penalty proceedings was not justified in the facts of the case. The entire facts were duly and correctly shown and there is neither any concealment of income nor furnishing of any inaccurate particulars of income and therefore the very initiation of the penalty proceedings in the case of the appellant is not justified." ....
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....erative society (though the said co-operative society is doing banking activities ) is allowable u/s 80P(2)(d) of the Act is already decided by the Jodhpur bench in the case of in the case ITO Vs. Bhilwara Zila Dugdh Utpadak Sahkari Sang Ltd., where in the finding of the co-ordinate bench is as under : 7. We have heard the both parties and perused the materials available on record. The Bench observed that the said appeal was filed on the basis of that addition of Rs. 2,23,46,187/- u/s 80P(2)(d) of the Act. We note that the department has preferred an appeal against the order of ld. CIT(A) for assessment year 2016-17 wherein the disallowance of deduction claimed u/s 80P(2)(d) of the Act amount to Rs. 2,23,46,187/- was deleted. The issue before us is that whether the assessee being co-operative society be denied benefit of section 80P(2)(d) of the Act on interest received from another cooperative society engaged in banking activities. The similar issue has been decided by the Hon'ble Rajasthan High court, Jodhpur has decided in Revenue's appeal filed for the assessment year 2014-15 in the case of PCIT, Ajmer vs M/s Bhilwara Zila Dugdh Utpadak Sahakari Sangh Ltd. in BD Income Tax Ap....
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....te proceeding and the identical issue which is in favour of the assessee's own case of the Coordinate Bench in case by the ITAT, Jodhpur's order dated 31.10.2018 in ITA No. 437/Jodh/2017, A.Y. 2014-15) which have been confirmed by the Hon'ble Court. The relevant observation of ITAT is as under:- "5. We have considered the rival submission of the parties and have gone through the assessment proceedings the AO noted that assessee has claimed exemption of interest income on FDR with Central Cooperative Bank Ltd., for Rs. 76,43.562/- and interest on FDR with Baroda Rajasthan Kshetriya Gramin Bank of Rs. 2,09,91,701 The AO allowed the exemption on interest received from Central Co-operative Bank However, the AO disallowed the exemption on account of interest earned from Baroda Rajasthan Kshetriya Gramin Bank on his observation that Baroda Rajasthan Kshetriya Gramin Bank is not a Co-operative Society. The 40 also took the view that Baroda Rajasthan Kshetriya Gramin Bank is neither registered under Co-operative Society Act or under, other law for the time enforce any such state for registration of Co-operative Societies. Therefore, the interest of Rx 2,09,91,701/- received on FDR was no....
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.... any Regional Rural Bank from assessment year 2007-08 onwards. An OM dated 25-8-2006 addressed to RBI was issued by the Board clarifying that Regional Rural Banks would not be eligible for deduction under section 80P of the Income-tax Act, 1961 from the assessment year 2007-08 onwards. 4. It has been bought to the notice of the Board that despite the amended provisions, some Regional Rural Banks continue to claim deduction under section 80P on the ground that they are cooperative societies covered by section 80P(1) read with Boards Circular No. 319 dated 11-1-1982. 5. It is, therefore, reiterated that Regional Rural Banks are not eligible for deduction under section 80P of the Income-tax Act, 1961 from the assessment year 2007-08 onwards. Furthermore, the Circular No. 319 dated 11-1-1982 deeming any Regional Rural Bank to be cooperative society stands withdrawn for application with effect from assessment year 2007-08. The field officers may take note of this position and take remedial action, if required. 7. We have also perused the various provisions of Regiona Rural Bank Act 1976. Baroda Rajasthan Kshetriya Gramina Bank was set up under the provisions of under the provisions of R....