This compilation indexes twelve rulings pronounced by the Income Tax Appellate Tribunal (ITAT) between December 2025 and April 2026, all engaging Section 80P(2)(a) of the Income Tax Act, 1961. The cases arise predominantly from appeals filed by cooperative credit societies — including employee cooperative societies, nagari sahakari patsansthas, gramin sahakari societies, and state-level cooperative banks — contesting the denial of deductions claimed on interest income, investments, and credit-facility receipts. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured index of recent ITAT positions on the cooperative society deduction provisions.

Research index only. This page catalogues publicly available tribunal orders for academic and professional reference. Nothing on this page constitutes legal or tax advice. Readers should verify every ruling against the full authenticated judgment text and check for any subsequent stay, reversal, or appeal before relying on it.

The statutory framework in one paragraph

Section 80P of the Income Tax Act, 1961 provides for deductions in respect of income of co-operative societies. Sub-section (2)(a) specifies the categories of income — broadly, profits and gains attributable to the business of a co-operative society engaged in activities such as carrying on the business of banking or providing credit facilities to its members, cottage industry, marketing of agricultural produce grown by members, and related activities — that are eligible for a full deduction in computing the total income of the society. The deduction operates at the level of the gross total income, and the scheme of Section 80P must be read alongside sub-sections such as 80P(2)(d) (relating to interest or dividend from other cooperative societies) and 80P(4) (which excludes co-operative banks other than primary agricultural credit societies and primary cooperative agricultural and rural development banks from the benefit of the section) to determine the precise scope of the exemption available to any given society in any given assessment year.

The 12 rulings

1. Onu General Insurance Employees vs Income Tax Officer( Ward 1 (4), Nagpur

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 13 April 2026
Sections engaged: 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 732/NAG/2025), pertaining to A.Y. 2015-16 and bearing PAN AAAAO0631J, was filed by the assessee against the order of the CIT(A)/NFAC dated 26.12.2024, which arose out of an Assessment Order dated 27.03.2022 passed under Section 143(3) r.w.s. 263 r.w.s. 144B of the Income Tax Act, 1961. The assessee's sole grievance was that the CIT(A) erred in denying the deduction under Section 80P(2)(a) for interest of Rs. 6,63,731/- earned on investments of surplus operational funds temporarily parked in fixed deposits with nationalised banks; the assessee contended that the issue was squarely covered by a consistent line of decisions favouring credit cooperative societies on such temporary deposits.

2. Jayant Bhise Nagri Sahakari Pat Sanstha vs ITO Ward 1 Yavatmal, Yavatmal

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 13 April 2026
Sections engaged: 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: This order disposed of three consolidated appeals — ITA Nos. 419, 421, and 611/NAG/2025 — involving separate credit cooperative societies (including Jayant Bhise Nagri Sahakari Patsanstha Maryadit, PAN AAAJ0156E, for A.Y. 2020-21), all raising a common issue against the denial of deduction under Section 80P(2)(a). The source preview records that the appellants are credit cooperative societies engaged in the business of accepting deposits and providing credit facilities to their members, and that the dispute centres on the denial of the deduction under Section 80P(2)(a) in each of the respective assessment years.

3. The Karnataka State Cooperative vs Income Tax Officer, Ward-5(2)(1)

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 9 April 2026
Sections engaged: 250, 56, 80P, 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1821/Bang/2025) relates to A.Y. 2022-23 and was filed by The Karnataka State Cooperative Agriculture and Rural Development Bank, Bengaluru (PAN AAAAT7773N). The text preview indicates that the Assessing Officer referred to the provisions of Section 80P and disputed the deduction in respect of multiple income streams, including interest on investments of Rs. 16,59,75,667/-, interest on other advances of Rs. 1,77,67,660/-, and other income of Rs. 83,31,614/-; the Tribunal noted at the outset that the issue of eligibility of deduction under these provisions was under examination.

4. M P Matsya Mahasangh Sahakari,Bhopal vs Assistant Commissioner Of Income-Tax

Bench: Income Tax Appellate Tribunal - Indore
Date: 27 March 2026
Sections engaged: 194A(3), 194A(3)(v), 263, 80P, 80P(2)(a), 80P(2)(d), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: Five consolidated appeals were filed by the assessee (M.P. Matsya Mahasangh Sahakari, PAN AAAAM0348J) covering multiple assessment years, including A.Y. 2015-16 (assessment order dated 28.03.2022 passed under Section 147 r.w.s. 144B) and A.Y. 2017-18 (assessment order dated 26.11.2019 passed by DCIT/ACIT-1(1), Bhopal under Section 143(3)). The appeals collectively raise issues under Section 80P, including the availability of deductions under Section 80P(2)(a) and related sub-provisions, as well as the applicability of Section 263 proceedings and Section 194A TDS provisions.

5. Adim Jati Sewa Sahkari Samiti Mydt vs Faceless Assessment Officer

Bench: Income Tax Appellate Tribunal - Indore
Date: 27 March 2026
Sections engaged: 194A(3), 194A(3)(v), 253(5), 263, 80P, 80P(2)(a), 80P(2)(d), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 663/Ind/2025) relates to A.Y. 2020-21 (PAN AAALA0577E) and was filed against the order of first appeal dated 04.11.2024 passed by the CIT(A)-NFAC, Delhi, arising out of an assessment order dated 13.09.2022 passed under Section 143(3). The registry noted that the present appeal was delayed by 181 days; the source preview indicates that the appeal engages questions under Section 80P(2)(a) and related provisions, alongside a condonation of delay issue under Section 253(5).

6. Ommi Sandeep,Vizianagaram vs Income Tax Officer, Ward-1

Bench: Income Tax Appellate Tribunal - Vizag
Date: 24 February 2026
Sections engaged: 139(1), 142(1), 144, 250, 80A, 80A(5), 80P, 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 247/VIZ/2025) for A.Y. 2017-18 was filed by The Chinnampeta Primary Agricultural Cooperative Credit Society Limited (PAN AACAT7997E) against the order dated 31.10.2025 passed under Section 250 by the CIT(A)-NFAC, Delhi. The appeal raises the deduction claim under Section 80P(2)(a) and the source preview records that the matter also engages provisions relating to Section 80A and Section 80A(5) in the context of the cooperative credit society's deduction entitlement for the relevant assessment year.

7. ITO, Satara vs Utkarsha Nagari Sahkari Patsanstha

Bench: Income Tax Appellate Tribunal - Pune
Date: 24 February 2026
Sections engaged: 263, 59(2), 80P, 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two Revenue appeals (ITA Nos. 2443 & 3121/PUN/2025) and a Cross Objection (CO No. 16/PUN/2026) filed by Utkarsha Nagari Sahakari Patsanstha Marya Wai (PAN AAAAU0544L) were heard together, pertaining to A.Y.s 2018-19 and 2022-23. The appeals are directed against the CIT(A)/NFAC orders dated 08.08.2025 and 24.10.2025 respectively, and the matter involves the deduction under Section 80P(2)(a) along with Section 263 proceedings initiated against the assessee cooperative society.

8. Nagpur District Shala Karmachari vs Income Tax Officer Ward 4 (4), Nagpur

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 19 February 2026
Sections engaged: 234A, 80P(2)(a), 80P(2)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: The two appeals (ITA Nos. 774 & 775/NAG/2025) relate to A.Y.s 2018-19 and 2020-21 and were filed by Nagpur District Shala Karmachari Credit Co-operative Society Ltd. (PAN AAALN0073A). The assessee had filed its return of income on 30.10.2018 declaring total income at Nil after claiming deduction under Section 80P(2)(a)(i); the Assessing Officer rejected the deduction claim on the ground that the assessee had earned interest by way of investment of funds in banks, following decisions of the Karnataka High Court cited in the assessment proceedings.

9. Shree Sant Savta Gramin Bigar Seti vs Assessing Officer, Nashik

Bench: Income Tax Appellate Tribunal - Pune
Date: 11 February 2026
Sections engaged: 144, 250, 56, 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1597/PUN/2025) for A.Y. 2016-17 (PAN AACAS4098M) was filed against the CIT(A)/NFAC order dated 27.11.2024 passed under Section 250, which itself arose from an assessment order dated 05.03.2024 passed under Section 144. The source preview notes that the assessee society is engaged in providing credit facilities to its members and accepting deposits from members only, and that the original assessment was preceded by a notice dated 23.03.2023 issued to the assessee on account of the assessee not having filed a return of income for A.Y. 2016-17.

10. Dharmaveer Sambhaji Nagari Sahakari vs PCIT, Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 16 January 2026
Sections engaged: 263, 66, 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1217/PUN/2025) for A.Y. 2020-21 was filed by a co-operative credit society registered under the Maharashtra Co-operative Societies Act (PAN AAAAD5228N), and all grounds raised by the assessee relate to the validity of Section 263 proceedings initiated by the PCIT. The Tribunal's order preview indicates that the substantive deduction issues under Section 80P(2)(a) are intertwined with the challenge to the Section 263 revisionary proceedings, and the text references a range of cited precedents on investments, advances, and Chapter VI-A deductions.

11. Deepalaxmi Nagari Patsanstha vs ITO Ward 2, Ahmednagar

Bench: Income Tax Appellate Tribunal - Pune
Date: 19 December 2025
Sections engaged: 2(n), 80, 80P, 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals (ITA Nos. 2322 & 2323/PUN/2024) for A.Y.s 2018-19 and 2020-21 were filed by Deeplaxmi Nagari Sahakari Patsanstha Maryadit, Sangamner (PAN AAAAD2548M). For A.Y. 2018-19, the assessee had filed its return of income on 13.10.2018 declaring gross total income of Rs. 65,21,355/- and total income of Nil after claiming deduction of Rs. 65,21,355/- under Section 80P; the return was selected for scrutiny, and statutory notice was thereafter issued, with the deduction claim under Section 80P(2)(a) forming the central dispute.

12. Dy. Commissioner Of Income Tax, Satara vs Shri Siddhanath Nagari Sahakari

Bench: Income Tax Appellate Tribunal - Pune
Date: 18 December 2025
Sections engaged: 133(6), 22(1)(b), 5(b), 56, 80P, 80P(2), 80P(2)(a), 80P(2)(c), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two Revenue appeals (ITA Nos. 1800 & 1801/PUN/2025) pertaining to A.Y.s 2018-19 and 2020-21 were directed against orders both dated 19.05.2025 of the CIT(A)/NFAC, Delhi. The assessee, Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi (PAN AAOAS0059G), is a co-operative society registered under the Maharashtra Co-operative Society Act, 1960; for A.Y. 2018-19, it e-filed its return of income on 16.10.2018 declaring total income of Rs. 4,03,690/- and claiming deduction of Rs. 5,15,931/- under Section 80P(2)(a)(i), with the Revenue's appeals contesting the CIT(A)'s allowance of such deduction.

Patterns across these 12 rulings

Concentration in Maharashtra-based cooperative credit societies. The overwhelming majority of appellants across these twelve rulings are cooperative credit societies registered under the Maharashtra Co-operative Societies Act, 1960. This geographic and entity-type clustering suggests that deduction denial under Section 80P(2)(a) has been a recurring audit and assessment action in Maharashtra jurisdictions, particularly at the Nagpur and Pune benches.
Interest on bank deposits and investments of surplus funds as the recurring flashpoint. Multiple cases — including Cases 1, 2, and 8 — specifically involve the denial of deduction on interest earned from investments of surplus or operational funds parked in fixed deposits with nationalised or cooperative banks. The question of whether such investment income qualifies for the Section 80P(2)(a) deduction appears repeatedly as the substantive controversy driving appeals.
Frequent involvement of Section 263 revisionary proceedings alongside the substantive deduction dispute. Cases 4, 7, and 10 each involve Section 263 proceedings initiated by the PCIT or Commissioner as part of the factual background, indicating that Section 263 revisionary action has been used as a mechanism to reopen or revisit cooperative society deduction allowances made at the assessment stage.
Multi-year consolidated appeals as a structural feature. Several orders in this compilation — Cases 2, 4, 7, 11, and 12 — disposed of two or more appeals in a single consolidated order covering different assessment years. This pattern reflects either the same substantive issue recurring across consecutive years for the same assessee, or multiple appellants raising identical questions being tagged and heard together.
Delay in filing and condonation as a threshold procedural issue. Case 5 (Adim Jati Sewa Sahkari Samiti Mydt) expressly records a delay of 181 days in filing the appeal, with the registry flagging this before the Tribunal could reach the substantive Section 80P(2)(a) question. This illustrates that procedural admissibility — separate from the merits of the deduction claim — can be a live issue in cooperative society appeals at the ITAT stage.

How to use this compilation

This compilation is designed as a starting-point research index, not a definitive statement of the law. Each entry above identifies the tribunal, bench, date of pronouncement, ITA number (where visible in the source preview), assessment year, and the sections engaged — sufficient to locate the full authenticated order on indiankanoon.org or the ITAT's official e-filing portal. Researchers should always retrieve and read the complete judgment text before drawing any conclusions about the ratio, since source previews may be truncated and may not capture the dispositive portion of the order.

Before placing reliance on any ruling listed here, it is essential to check whether the order has been challenged before the High Court or the Supreme Court, whether any interim stay has been granted, and whether a contrary or distinguishing ruling has been issued by a coordinate or superior bench on the same point. The Section 80P(2)(a) deduction landscape has been subject to evolving judicial positions — including on questions such as the treatment of interest from bank deposits, the applicability of Section 80P(4) to various classes of cooperative societies, and the interaction with Section 80A(5) — and a single ITAT order should not be read in isolation from the broader precedent stream.

Additionally, researchers should cross-check the factual matrix of each ruling against CBDT instructions, circulars, and notifications relevant to cooperative society taxation, including any clarifications on the scope of "banking" activities for the purposes of Section 80P(2)(a). Where the dispute involves TDS provisions or revisionary proceedings under Section 263, the applicable procedural norms and limitation periods should be independently verified against the current statutory text and any binding High Court authority in the relevant jurisdiction.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 80P(2)(a) Deduction for Cooperative Societies: 12 ITAT Rulings (2025–2026)