Section 80P(4) not applies to primary agricultural credit societies not entitled for banking license

Sahyadri Vividdhodesha Areca Vs ITO (ITAT Bangalore) Held that object of section 80P(4) was to exclude co­operative banks that function at par with other commercial banks and noted that as primary agricultural credit societies are not entitled for obtaining a banking license would not be hit by this provision. Facts- Assessee is a society registered under the Karnataka Co-operative Societies Act, 1959. The Assessee claimed deduction u/s.80P(2)(a)(i) of the Act. According to the Asessee it did not have license to carry on any banking business under the Banking Regulation Act, 1949. It was enga...