The assessee, a co-operative society, was denied deduction under section 80P on the ground that it was a co-operative bank within the meaning of section 80P(4). The Tribunal held that merely because the word “bank” formed part of the assessee’s name, it could not be treated as a co-operative bank in the absence of a banking licence issued under the Banking Regulation Act. Since the assessee was not carrying on banking business as contemplated under the Banking Regulation Act, the Department was not justified in denying deduction merely on nomenclature. Accordingly, the assessee was held entitled to a deduction under section 80P. The Tribunal further observed that any disallowance of gratuity contribution resulting in enhancement of business profits would also qualify for deduction in view of CBDT Circular No. 37 of 2016 (AY. 2015-16)