Assessee-society was engaged in marketing of sugarcane produced by its members. It received commission from sugar mills on supply of sugarcane by its members. Assessing Officer held  that commission received by assessee was assessable under head income from other sources and not as income from business and, thus, deduction under section 80P was not allowable.  CIT(A) allowed the deduction. On appeal the Tribunal held that  both Cane Development Councils or Cooperative Cane Development Unions (Cane Growers Cooperative Society or Societies) performed an important role in cane production and marketing in a particular area or zone. Unions were directly involved in marketing of sugarcane to various factories, Council performed a number of functions to facilitate production and supply of sugarcane in area assigned to it. Payment of commission by occupier of factory or by Gud, Rub or Khandsari units was not on account of some investment that was made by these Councils or Unions with factories but rather because of their role in production and marketing of sugar cane in that particular area and was attributable to activity of production and marketing of sugarcane for which Cane Development Councils and Co-operative Cane Development Unions had been set up under Sugarcane Act and Rules. On facts, commission received by assessee was business receipts and, thus, eligible for deduction under section 80P. (AY. 2013-14, 2014-15, 2015-16, 2017-18)