Held that the assessee was not a bank according to the definition of section 5(c) of the Banking Regulation Act, 1949.  The assessee did not fall under the exception under section 80P(4). That with regard to interest earned from credit facilities, staff loans and investments made, the Karnataka Co-operative Societies Act, 1959 defined “members” to include nominal and associate members under section 2(f). Therefore, the assessee qualified for deduction under section 80P(2)(a)(i) in respect of the interest earned from credit facilities extended to nominal and associate members. That according to section 80P, an income which was attributable to any of the specified activities in section 80P(2) of the Act could only be eligible for deduction. Providing loans to the employees could not be considered as, “attributable” to the business of the assessee. The term “attributable to the business” is a much narrow term, which is directly connected to the objects of the assessee for which it has been established. Therefore, the interest earned by the assessee from loans given to its employees could not be considered for deduction under section 80P(2)(a)(i) of the Act and had to be treated as income from other sources. That there was nothing on record to come to the conclusion that the amount which was invested in banks to earn interest was an amount due to its members, and was a liability. This amount which was in the nature of profits and gains, was not immediately required by the assessee for the objects of the society, but was required to be invested as required by the Karnataka Co-operative Societies Act, 1959. Therefore it had deposited the money out of which interest was earned. The interest was thus attributable to carrying on the business of the assessee. The Assessing Officer was to verify whether interest was received by the assessee out of investments made with co-operative societies. If the assessee had earned interest income out of investments with co-operative society, it was entitled to deduction under section 80P(2)(d) of the Act. If the interest was earned from the banks, it had to be considered under the head “Income from other sources” and necessary relief to be granted to the assessee under section 57 of the Act in respect of cost of funds and proportionate administrative and other expenses in accordance with law. Accordingly, the issue was restored to the file of the Assessing Officer for de novo consideration. That the guarantee commission could not be considered to be in the nature of any levy, cess of such type. The provisions of section 43B would not be admissible to the payment of guarantee commission by the assessee to the State Government under an agreement as it did not qualify for any of the types mentioned therein. Therefore, the issue was remanded to the Assessing Officer to carry out necessary verification, based on the agreement entered into by the assessee with the Government and to analyse if the payment of guarantee commission was an admissible deduction under section 37(1) of the Act. That the income earned by the assessee from e-stamping services could not be considered for the purpose of deduction under section 80P(2) of the Act. However, the Assessing Officer was to consider the alternative claim of the assessee in accordance with law and proper opportunity of being heard to be granted to the assessee.  That the issue regarding incorrect quantification of total income, the Assessing Officer was to quantify total income, in accordance with law in the light of evidence filed and proper opportunity of being heard to be granted to the assessee.  That it was submitted that nothing had been decided by the Commissioner (Appeals) on the merits on the ex parte orders passed by the Commissioner (Appeals). As the issue regarding the eligibility to claim deduction under section 80P(2)(a)(i) / (d) of the Act was principally considered, these appeals were also to be analysed by the Assessing Officer on similar basis. (AY. 2012-13 to 2018-19, 2020-21)