2025 (1) TMI 1725

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....PER: INTURI RAMA RAO, AM These appeals filed by the assessee are directed against separate orders of the National Faceless Appeal Centre, Delhi [CIT(A)] dated 01.08.2023, 11.08.2023 & 01.08.2023 for Assessment Years (AYs) 2010-11, 2012-13 & 2016-17, respectively 2. Since identical issues are involved, these appeals are heard together and disposed of vide this common order. 3. Brief facts ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....t in the case of Pr.CIT v. Mavilayi Service Co-operative Bank Ltd. [2019] 414 ITR 67 (Ker) (FB). 4. Being aggrieved, an appeal was filed before the CIT(A), who wide the impugned order held that the assessee is co-operative bank and accordingly denied exemption by placing reliance on the provisions of sub-section (4) of section 80P of the Act. 5. Being aggrieved, assessee is in appeal before ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nch judgement of the Hon'ble Kerala High Court in the case of Mavilayi Service Co-op. Bank Ltd. (supra). We find that the Full Bench decision of the Hon'ble Kerala High Court was overruled by the Hon'ble Supreme Court in the case of Mavilayi Service Co-operative Bank Ltd. v. CIT reported in [2021] 431 ITR 1 (SC) wherein it was held that once a co-operative society is registered as a pr....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... any restriction or limitation cannot be restricted or limited by implication, as is sought to be done by the Revenue in the present case by adding the word "agriculture" into section 80P(2)(a)(i) when it is not there. Further, section 80P(4) is to be read as a proviso, which proviso now specifically excludes cooperative banks which are co-operative societies engaged in banking business, i.e., eng....