Tribunal held that the Assessing Officer had concluded that out of the total loan disbursed by the assessee only 12.54 per cent. was for agricultural purpose or allied activities. His finding was not conclusive unless each loan application and loan ledger was verified and after necessary verification he had to conclude that the assessee was not engaged primarily in providing credit facilities for agricultural purpose or allied activities. Therefore, the Assessing Officer shall examine the activities of the assessee afresh and determine whether the activities were in compliance with the activities of a co-operative society functioning under the 1969 Act and accordingly grant deduction under section 80P(2) .( AY.2014-15)
Ayalur Service Co-Operative Bank Ltd. v. ITO (2020) 79 ITR 17 (SN) ( Cochin) (Trib)
S. 80P : Co-operative societies – Agricultural purpose or allied activities- Matter remanded to the AO to examine activities of assessee afresh and determine whether activities in compliance with activities of Co-Operative Society functioning under Kerala Co-Operative Societies Act, 1969 and to grant deduction. [S.80P(2), Kerala Co-operative Societies Act, 1969. ]