Assessee, a co-operative credit society, earned commission income from collecting electricity bills for MSEDCL (Maharashtra State Electricity Distribution Company Limited) and locker rent charges from its members. AO disallowed the deduction claimed under section 80P(2)(c), treating the commission income as ‘Income from Other Sources.’ Assessee argued that the income was derived from services rendered to members and was eligible for deduction, supported by audited accounts and expense details (salaries, electricity charges, etc.).The commission income was attributable to services provided to members and was duly verified. The expenses incurred were directly linked to the income, and the accounts were audited by the Maharashtra State Cooperation Ministry. The income qualified under section 80P(2)(c) as it was incidental to the society’s primary credit activities. (AY. 2017 -18) (ITA No. 990/Mum/2025, dt.30/04/2025 )