2026 (3) TMI 1013

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....pondent : Shri Surendra Mohan (SR. DR) ORDER PER BENCH : Both the appeals of the same assessee are preferred against the order of the Ld. Commissioner of Income Tax, Appeal, ADDL/JCIT (A) Kochi [for brevity the "Ld. CIT(A)"], order passed under section 250 of the Income Tax Act 1961 (for brevity 'the Act') for Assessment Year 2020-21 to 2021-22 date of order 31.10.2025. The impugned order....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....out of same factual matrix. These appeals were heard together as a matter of convenience and are being decided by way of this consolidated order. So, with the consent of Ld. DR ITA No. 9179/Mum/2025 is taken as lead case and the decision rendered therein shall apply mutatis mutandis to other appeal before us. 4. We heard the rival submission and considered the documents available in the record.....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d that the assessee had placed the deposited in the Cooperative Bank. The interest earned from Cooperative Bank was claimed as deduction u/sec 80(P)(2)(d) of the Act. The said issue is no more res integra. It is noted in the ground of appeal that the said claim of deduction is duly allowed by Coordinate Bench of ITAT Mumbai in the other cases. The assessee respectfully placed reliance on the order....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....saheb Patil Mathadi Kamgar Sahakari Pathpedi Limited, reported in (2023) 150 taxmann.com 173 (SC) and Kerala State Co-Operative Agricultural And Rural Development Bank Ltd. KSCARDB vs. Assessing Officer, reported in [2023] 458 ITR 384 (SC) where the Hon'ble Apex Court categorically stated that cooperative bank is the cooperative society and not acted as Bank under Banking Regulation Act,1949. We n....