The assessee has 646 members which are primary co-operative societies. These primary co-operative societies have the members such as farmers, their family members and other rural family unit. These primary cooperative societies are procuring milk from the members and in turn supplying to the assessee being a single society in the district. Thereafter the assessee is supplying the milk to the mother dairy. The assessee claimed that all the activities involved in the supply of milk to the mother dairy are controlled as per the direction of Gujarat Milk Marketing Federation (For short GMMF). Accordingly the assessee claimed to be eligible for claiming the deduction under section 80P(2)(b) of the Act and hence claimed the deduction of 1 1142336.00 only.  The AO was not satisfied with the claim of the assessee on the ground that such deduction is available to the primary co-operative societies. As such the assessee is the district level society and therefore the same cannot be held eligible for deduction under section 80P(2)(b) of the Act. Accordingly the AO disallowed the deduction of 1,11,42,336.00 claimed and added to the total income of the assessee. CIT (A) affirmed the order of the Assessing Officer . On appeal the Tribunal held that  it appears that the assessee is not the primary co-operative society but its activities are depending upon the primary co-operative societies. As such the primary co-operative societies can also not operate without the assessee being a district level society. As such the activities of the assessee are interlinked with the activities of the primary co-operative societies . Moreover, the primary co-operative societies will be eligible only when they supply milk to a federal co-operative society accordingly the provisions of section 80P(2)(b) of the Act should be read liberally followed Broach Distt Co-operative Cotton Sales, Ginning & pressing Society Ltd. v. CIT  (1989 ) 177 ITR 418 (SC)   (AY.  2012-13, 2013-14)