Kolhapur District Central Co-op Bank Kanista Sevakanchi Sahakar Pat Sanstha Ltd. v. ITO [2024] 205 ITD 6 (SMC) (Pune) (Trib)

S.80P: Co-operative societies -Interest – Surplus funds -Co -Operative banks and Schedule banks -Eligible deduction. [S.80P(2)(a)(i), 80P(2)(d)]

AO disallowed the claim for deduction of interest income earned on fixed deposits made with bank by holding it to be a co-operative bank.  CIT(A) affirmed the order of the AO. On appeal the Tribunal held that  even the co-operative bank as well as schedule bank qualifies for deduction both under provisions of section 80P(2)(a)(i) and section 80P(2)(d) and therefore the reasoning given by the lower authorities on this issue cannot be accepted.  (AY. 2018-19)