Held that  Tribunal had recorded a clear finding of fact that the assessee had come into existence for development and growth of the agricultural sector. This finding of fact had not been disputed. The assessing authority himself had recorded a finding that the assessee came into existence with effect from March 31, 2008, after amalgamation of two regional rural banks. By virtue of the deeming provision under section 22 of the Regional Rural Banks Act, 1976, the assessee was deemed to be a co-operative society. The assessee was entitled to special deduction under section 80P of the Income-tax Act, 1961. Court also affirmed the deletion of penalty u/s 271(1)(c) of the Act. (AY.2012-13 to 2016-17)