TaxTMI 
TaxTMI 
2025 (6) TMI 955
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.... same rather one appeal has mistakenly been filed . 2. Brief facts of the case of the assessee are that the assessee is a co-operative society registered under Co-operative Societies Act and Rules, filed its return of income for AY 2018-19 declaring total income at Rs. 29,55,350/- and revised return have also been filed declaring total income same. The case was selected for scrutiny, notice u/s 143(2) was issued. Notice u/s 142(1) of the Act along with questionnaire was also issued to the assessee calling for details, documents and evidences in support of income. The assessee submits his submission but the AO did not find the submission being tenable, accordingly, the AO made disallowance u/s 80P of the Act, an amount of Rs. 5,06,94,148/- ....
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....further submits that the assessee is trying to operate his service, margin technology services i.e. RTGS and NEFT services. The Ld. Counsel submits that the question of violating the norms of Section 80P(2)(a)(i) of the Act does not arise. 6. Upon hearing the submission of the Counsel for the counsel for the respective parties, we have perused the order of AO as well as Ld. CIT(A). In the present case the AO has added an amount of Rs. 5,06,94,848/- after disallowance u/s 80P of the Act. There is no dispute that the assessee is a co-operative society registered under Cooperative Societies Act and Rules and as per the Circular No. 6/2010 deduction u/s 80P of the Act is allowable only to a primary agricultural credit society or Primary Cooper....
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....ction 80P(4) is out of harm's way, all the assessee in the present case are entitled to the benefit of the deduction contained in Section 80P(2)(a)(i), notwithstanding that they may also be giving loans to their members which are not related to agriculture. Also in case it is found that there are instances of loans being given to non-members profit attributable to such loans obviously cannot be deducted." 7. In the present case, we find that the object of the assessee is to make income from carrying on banking business for its members and income from providing credit facilities to its members. The Ld. CIT(A) has discussed the object of the primary agricultural society in its order and according to him the primary object or pre-business of....