2026 (2) TMI 497

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....Order passed by the National Faceless Appeal Centre, Delhi dated 23.06.2025 wherein the Appeal filed by the Assessee against the Assessment Order passed u/s. 143(3) of the Income Tax Act, 1961 (the Act) by the Income Tax Officer, Ward-2, Chikmagalur (the Ld. Assessing Officer) dated 27.07.2019 was dismissed. The Assessee aggrieved with the same has preferred this Appeal. 2. The issue is that Assessee has been denied deduction being the Primary Co-operative Agricultural and Rural Development Bank u/s. 80P of the Act. The brief facts of the case shows that the Assessee filed its return of income on 28.10.2017 wherein the gross total income of Rs. 39,92,145/- and total income of Rs. Nil/- were shown claiming deduction of Rs. 39,92,145/- u/s....

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....s primary co-operative agricultural and rural development bank and therefore the Assessee is entitled to deduction u/s. 80P of and is not precluded by virtue of section 80P(4) of the Act. With respect to the deduction u/s. 80P(2)(a)(i), he submits that Assessee is in the business of providing credit facilities to its members and therefore the income is attributable to that business and hence eligible for deduction. With respect to deduction u/s. 80P(2)(c)(ii), it was submitted that e-stamping income is received by the Assessee which is less than 1% of the total income and therefore it falls in the category of any other income of the co-operative society and hence deductible. 5. The Ld. Departmental Representative Shri Ganesh R Ghale, Adv....