From the reading of Sec. 80P(4) it is apparent that this section denies deduction to a co-operative bank other than a primary agricultural credit society or primary co- operative agricultural and rural development bank.
Government only intended to restrict the investment in a particular financial year and accordingly has fixed the limit of Rs. 50,00,000/- as permissible limit in a particular financial year. The Government did not intend to restrict the maximum amount of exemption permissible under Section 54EC.
The question arises is whether the assessee is entitled for the deduction under section 80P(2)(a)(i). Section 80P(2)(a)(i) is explicitly clear that if the co-operative society is engaged in the business of banking or providing credit facilities to its members the co-operative society is entitled for the deduction. There is an embargo put by section 80P(4) which was introduced into the statute by the Finance Act, 2006 with effect from 1-4-2007. This section denies the deduction to a co-operative bank. It is a fact that prior to the insertion of sub-section (4) ,the assessee was getting the deduction under section 80P(2)(a)(i).
