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Deduction U/s 80P(2)(d) Allowed on Interest from Co-operative Bank – ITAT Mumbai

Case Law Details

TaxGuru Citation
2026 taxguru.in 3351
Case Name
Matruchhaya Commercial Premises Co-OP Society Ltd. Vs ITO (ITAT Mumbai)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2020-21
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Matruchhaya Commercial Premises Co-OP Society Ltd. Vs ITO (ITAT Mumbai)

Deduction u/s 80P(2)(d) Allowed on Interest from Co-operative Bank – ITAT Mumbai

Assessee, a Co-op Society, earned interest of ₹1.41 lakh from deposits with a Co-operative Bank & claimed deduction u/s 80P(2)(d). CPC disallowed the claim u/s 143(1) & rejected rectification u/s 154. CIT(A) also upheld the disallowance.

ITAT noted that issue is settled & relied on SC rulings holding that Co-operative Bank qualifies as Co-operative Society for purposes of section 80P. Accordingly, interest earned from such deposits is eligible for deduction u/s 80P(2)(d).

Addition made by AO was quashed & appeal of assessee allowed.

FULL TEXT OF THE ORDER OF ITAT MUMBAI

Both the appeals of the same assessee are preferred against the order of the Ld. Commissioner of Income Tax, Appeal, ADDL/JCIT (A) Kochi [for brevity the “Ld. CIT(A)”], order passed under section 250 of the Income Tax Act 1961 (for brevity ‘the Act’) for Assessment Year 2020-21 to 2021-22 date of order 31.10.2025. The impugned orders emanated from the order of the CPC Bengaluru (for brevity the ‘Ld. AO’) order passed under section 154 of the Act date of order 29.06.2022 for A.Y. 2020-21 and 17.02.2022 for 2021-22.

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,513

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