ITAT Bangalore Recognized Nominal Members for 80P Deduction

Sullia Primary Co-operative Agricultural & Rural Development Bank Vs ITO (ITAT Bangalore) Assessee, a primary agricultural co-operative credit society registered under Karnataka Co-operative Societies Act, filed appeals against orders of CIT(A), NFAC dated 08.01.2025. 80P Deduction Issue: AO denied deduction of ₹1.27 crore claimed u/s 80P(2)(a)(i) on ground that majority of business was conducted with B-class nominal members, who lacked voting & profit-sharing rights. AO held that principle of mutuality was violated, relying on Citizen Co-operative Society Ltd. (2017) 397 ITR 1 (SC) ...