TaxTMI 
TaxTMI 
2026 (8) TMI 1765
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.... Appeals ["Ld.CIT(A)], National Faceless Appeal Centre (NFAC), Delhi vide DIN: ITBA/NFAC/S/250/2025-26/1080315334(1) dated 03.09.2025 for the Assessment Year 2020-21. 2. The brief facts of the case are that the assessee, 12478 Pedakakani Primary Agricultural Co-op Society Ltd is an agricultural co-operative society, registered under the Co-operative Societies Act, 1912. The assessee filed it's return of income for the A.Y.2020-21 on 15.01.2021, declaring total income of Rs. Nil after claiming deduction u/s 80P(2)(a)(i) of the Income Tax Act, 1961 ("the Act"). The case was selected for scrutiny and assessment has been completed u/s 147 r.w.s.144 of the Act on 06.01.2025 and determined the total income of Rs. 10,19,560/- by making addition....
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....ted 19.06.2026 submitted that, this issue is covered in favour of the assessee by the decision of the Tribunal, where deduction u/s 80P(2)(d) was allowed in respect of interest earned from deposits made with co-operative banks. Therefore, he submitted that the addition made by the AO should be deleted. 6. Shri A.P.Babu, Ld.Sr.AR for the Revenue, supporting the order of the AO and CIT(A) submitted that, interest earned by a cooperative society from any other cooperative society is exempt u/s 80P(2)(d) of the Act, but if any cooperative society receives interest income from a cooperative bank, the same is not exempt in view of the provisions of section 80P(4) of the Act. He, therefore, submitted that the order of the Ld.CIT(A) should be up....
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.... Co-operative Bank and earned interest income. Further, Guntur District Co-operative Bank is also a registered co-operative society under the Co-operative Societies Registration Act, 1912. Since appellant society earned interest income from its deposits with another cooperative society, the interest income is exempt u/s 80P(2)(d) of the Act. The Ld.CIT(A), without appreciating relevant facts, simply sustained the addition made by the AO. Thus, we set aside the order of the Ld.CIT(A) and delete the addition made by the AO towards interest income of Rs. 10,19,558/- u/s 80P(2)(d) of the Act. 8. In the result, appeal filed by the assessee is allowed. ITA No.785/Viz/2025, A.Y.2020-21 9. This appeal is filed by the Assessee against the o....
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.... Rs. 28,91,884/- and interest income of Rs. 3,94,916/- earned on deposits with KDCC Bank (a co-operative bank). The case was selected for scrutiny and assessment has been completed u/s 143(3) r.w.s.144B of the Act on 21.09.2022 by allowing deduction of Rs. 28,91,884/- under Chapter VIA-A Deduction u/s 80P of the Act and determined the total income of Rs. 3,94,916/- by making addition of Rs. 3,94,916/-, towards interest received by the appellant society from its deposit with KDCC Bank u/s 80P(2)(d) of the Act. 13. Aggrieved by the assessment order, the assessee preferred an appeal before the CIT(A) and challenged the additions made by the AO towards interest income u/s 80P(2)(d) of the Act and claimed that the appellant company, a primary....
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....t earned by a cooperative society from any other cooperative society is exempt u/s 80P(2)(d) of the Act, but if any cooperative society receives interest income from a cooperative bank, the same is not exempt in view of the provisions of section 80P(4) of the Act. He, therefore, submitted that the order of the Ld.CIT(A) should be upheld. 16. We have heard both the parties, perused the material on record and had gone through the orders of the authorities below. The provisions of section 80P(2)(d) deals with interest or dividends received by the co-operative society from its investments with any other co-operative society and in case any cooperative society receives any interest income from any other cooperative society, then the same is e....