2025 (4) TMI 33

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....ER SANDEEP SINGH KARHAIL, JM : 1. The assessee has filed the present appeal challenging the impugned order dated 31/07/2024, passed under section 250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, ["learned CIT(A)"], for the assessment year 2017-18. 2. When this appeal was called for hearing, neither anyone app....

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....duction under section 80P of the Act. The return filed by the assessee was selected for scrutiny, and vide order dated 29/12/2019 passed under section 143(3) of the Act, the AO held that the assessee is not a primary agricultural credit co-operative society and accordingly disallowed the deduction claimed under section 80P of the Act. The AO noted that out of the total loans granted by the assesse....

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....ion 80P(4) of the Act held that section 80P(4) is a proviso to the main provision contained in section 80P(1) and (2) and excludes only Co-operative Banks, which are Cooperative Societies and also possesses a licence from RBI to do banking business. The Hon'ble Supreme Court further held that the limited object of section 80P(4) is to exclude Co-operative Banks that function at par with other comm....