This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings — spanning February 2025 to December 2025 — in which co-operative societies and co-operative banks were parties to disputes centred on the deduction provisions under Section 80P(2) of the Income Tax Act, 1961. The rulings arise from benches across Pune, Visakhapatnam, Cochin, Nagpur, Rajkot, Dehradun, and Chandigarh, and cover assessment years ranging from AY 2012-13 to AY 2021-22. This page is intended for in-house tax teams, Big-4 associates, and law firm researchers who require a structured reference index for quickly identifying fact patterns and procedural postures in Section 80P(2) litigation.

Research index only. This page is a structured case-law reference and does not constitute legal or tax advice. Readers must verify each ruling against the full judgment text and check for any subsequent stays, appeals, or reversals before placing reliance on it.

The statutory framework in one paragraph

Section 80P of the Income Tax Act, 1961 provides a deduction in computing the total income of a co-operative society. Sub-section (2) enumerates the specific categories of income eligible for this deduction, including: under clause (a), profits and gains attributable to certain business activities such as banking or providing credit facilities to members; under clause (c), income from cottage industries; and under clause (d), interest or dividends derived by a co-operative society from its investments with any other co-operative society. Sub-section (4), inserted by the Finance Act, 2006 with effect from AY 2007-08, excludes co-operative banks (other than primary agricultural credit societies or primary co-operative agricultural and rural development banks) from the benefit of Section 80P, to the extent that they are engaged in the business of banking or providing credit facilities to their members. The interaction between sub-section (2) and sub-section (4), the classification of a co-operative entity, and the nature of the income earned are recurring flashpoints in litigation under this provision.

The 12 rulings

1. 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: These two Revenue appeals (ITA Nos. 1800 & 1801/PUN/2025) were filed against two separate orders of the CIT(A)/NFAC, Delhi pertaining to AY 2018-19 and AY 2020-21, and were heard together and disposed of by a common order on account of identical issues. The assessee is a co-operative society registered under the Maharashtra Co-operative Society Act, 1960, which e-filed its return of income for AY 2018-19 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) of the Income Tax Act, 1961. The appeal was heard on 11 November 2025 and the order was pronounced on 18 December 2025.

2. The West Godavari District Co Op vs Principal Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Vizag
Date: 27 October 2025
Sections engaged: 142(1), 143(2), 143(3), 144B, 263, 80P, 80P(2), 80P(2)(a), 80P(2)(c), 80P(2)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed this appeal (ITA No. 356/VIZ/2025) against an order dated 27/03/2025 passed under Section 263 of the Income Tax Act, 1961 by the Principal Commissioner of Income Tax - I, Visakhapatnam, for AY 2020-21. The sole dispute raised by the assessee in this appeal is against the invocation of revisional jurisdiction by the learned PCIT under Section 263, in a matter that involved questions touching upon the deduction claimed under Section 80P(2). The order was pronounced in open court on 27 October 2025.

3. Avinissery Service Co-Operative Bank vs ITO, Ward 2(1),Thrissur, Thrissur

Bench: Income Tax Appellate Tribunal - Cochin
Date: 27 October 2025
Sections engaged: 133(6), 143(3), 2(19), 250, 80P, 80P(2), 80P(2)(a), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: These are two appeals preferred by the assessee (ITA Nos. 556 & 569/COCH/2025) pertaining to AY 2016-2017, both challenging an order of the Income Tax Officer, Ward 2(1), Thrissur. The appeals were heard together and disposed of by a consolidated order, with the hearing concluding on 21 August 2025 and the order pronounced on 10 September 2025 per the source preview. The appeals involve questions concerning deduction eligibility under Section 80P(2)(a) and the applicability of Section 80P(4) to the assessee entity.

4. The Rudrapaka Primary Agricultural vs Income Tax Officer, Ward-1, Gudivada

Bench: Income Tax Appellate Tribunal - Vizag
Date: 17 October 2025
Sections engaged: 80P, 80P(2), 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 162/Viz/2024) was filed by the assessee — Rudrapaka Primary Agricultural Cooperative Society Limited H1249, Machilipatnam — against the order of the CIT(A), NFAC, Delhi, relating to AY 2021-22. The assessee filed its return of income for AY 2021-22 on 11 July 2022, declaring total income at Rs. Nil after claiming deductions under Section 80P(2)(a). The hearing concluded on 14 October 2025 and the order was pronounced on 17 October 2025.

5. DCIT Akola Circle, Akola, Akola vs The Akola Janata Commercial

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 22 September 2025
Sections engaged: 143(1), 143(3), 154, 80P(2), 80P(2)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: This Revenue appeal (ITA No. 189/Nag./2025) for AY 2020-21 was filed against an impugned order dated 03/02/2025 passed by the CIT(A), NFAC, pertaining to The Akola Janata Commercial Co-operative Bank Ltd. (PAN: AAAAT0875H). The appeal was heard on 24 June 2025 and the order pronounced on 22 September 2025; the sections engaged include Section 80P(2)(d), which relates to interest or dividends derived from investments with other co-operative societies. The source preview indicates the order reproduced income tax slab provisions in the body of the order.

6. Shree Jamnagar Jilla Sahakari Kharid vs DCIT-Cir-2(1), Jamnagar

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 16 May 2025
Sections engaged: 142(1), 143(3), 250, 263, 80P(2), 80P(2)(a), 80P(2)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: This assessee appeal (ITA No. 223/RJT/2025) for AY 2018-19 was directed against an order passed under Section 250 by NFAC/CIT(A), Delhi dated 18.02.2025, which in turn arose from an order passed by the National e-Assessment Centre, Delhi on 17.04.2021. Issues raised in the appeal included investments/advances/loans, unsecured loans, and deduction from total income under Chapter VI-A, engaging questions under Section 80P(2)(a) and Section 80P(2)(d). The hearing was held on 14 May 2025 and the order pronounced on 16 May 2025.

7. Laksar Co Operative Cane Dev. Union vs ITO, W- 1(3)(4), Roorkee, Roorkee

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 7 May 2025
Sections engaged: 143(1), 154, 80P, 80P(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This assessee appeal (ITA No. 121/DDN/2024) for AY 2019-20 was directed against the order dated 14.05.2024 of the CIT(A), NFAC, New Delhi. The assessee, a co-operative society, filed its income tax return for the relevant year on 24 August (year partially visible in the source preview) and the dispute concerns the deduction claimed under Section 80P(2). Per the source preview, the assessee's income items included interest from savings/fixed accounts of Rs. 13,15,940/-, receipts from a sugar mill as per Form 26AS of Rs. 5,57,33,780/-, and interest on income tax refunds of Rs. 30,285/-; the hearing and pronouncement both took place on 07 May 2025.

8. The Kundara Panchayath Service vs Income Tax Officer, Ward 4, Kollam

Bench: Income Tax Appellate Tribunal - Cochin
Date: 29 April 2025
Sections engaged: 22, 80P, 80P(2), 80P(2)(a), 80P(2)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: Three appeals (ITA Nos. 802, 803 & 805/Coch/2024) were filed by The Kundara Panchayath Service Co-operative Bank Ltd. (PAN: AAFAT9868B), Kollam, pertaining to AY 2012-13, AY 2017-18, and AY 2018-19. The source preview reproduces statutory text relating to Section 80P(2)(d) — concerning interest or dividends derived from investments with other co-operative societies — and discloses interest income on deposits held with institutions including Trivandrum District Co-operative Bank (Rs. 9,28,68,899), Kerala State Co-operative Bank (Rs. 6,21,881), and District Treasury (Rs. 5,43,014). The hearing was held on 30 January 2025 and the order pronounced on 29 April 2025.

9. Sultanpur Juth Seva Sahakari Mandali vs The DCIT, Circle-1 (1), Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 27 February 2025
Sections engaged: 142(1), 143(3), 263, 270A, 80P, 80P(2), 80P(2)(a), 80P(2)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: Three assessee appeals (ITA Nos. 492, 493 & 697/RJT/2024) pertaining to AY 2018-19 and AY 2020-21 were filed against separate orders of the CIT(A), Rajkot, which in turn arose from separate assessment orders. The issues raised include investments/advances/loans, unsecured loans, and deduction from total income under Chapter VI-A engaging Section 80P(2)(a) and Section 80P(2)(d). Section 263 and Section 270A appear among the sections cited in the source, indicating revisional proceedings and penalty-related questions were also in play. The hearing was on 26 February 2025 and the order pronounced on 27 February 2025.

10. Rajura Nagari Sahakari Pat Sanstha vs Office Of The Income Tax Officer Ward 5

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 25 February 2025
Sections engaged: 143(2), 80P, 80P(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This assessee appeal (ITA No. 483/Nag./2024) for AY 2016-17 was filed against an impugned order dated 02/05/2023 of the CIT(A), NFAC, Delhi. As per the source preview, the assessee raised grounds asserting that the AO and CIT(A) ought to have allowed the deduction under Section 80P as claimed in the return of income, and separately alleged that the CIT(A) erred in not providing sufficient opportunity of being heard. The hearing was held on 04 February 2025 and the order pronounced on 25 February 2025.

11. Sri Lakshmi Venkateswara Mutually vs Income Tax Officer, Ward-1(1)

Bench: Income Tax Appellate Tribunal - Vizag
Date: 20 February 2025
Sections engaged: 142(1), 143(3), 80P, 80P(2), 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: This assessee appeal (ITA No. 140/VIZ/2024) for AY 2018-19 was filed against the order of the Income Tax Officer, Ward-1(1), Visakhapatnam. Per the source preview, the issues in the appeal included investments/advances/loans and deductions from total income under Chapter VI-A, with Section 80P(2)(a) being among the provisions engaged. The hearing concluded on 06 February 2025 and the order was pronounced on 20 February 2025.

12. The Jyoti Co-Operative Non vs ITO, Ward, Nahan

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 12 February 2025
Sections engaged: 142(1), 80P(2), 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: Three assessee appeals (ITA Nos. 160, 161 & 162/Chd/2023) pertaining to AY 2017-18, AY 2012-13, and AY 2013-14 were filed against respective orders of the CIT(A)/NFAC Delhi each dated 27/01/2023. Since all appeals involved a common issue, they were heard together and disposed of by a consolidated order, with ITA No. 161/Chd/2023 for AY 2012-13 taken as the lead case. Per the source preview, the assessee is a co-operative society engaged in providing services, with Section 80P(2)(a) being the primary deduction provision in dispute. The hearing was held on 07 January 2025 and the order pronounced on 12 February 2025.

Patterns across these 12 rulings

Dominance of NFAC as the first appellate authority. Across a majority of these cases, the impugned order before the ITAT was passed by the CIT(A)/NFAC, Delhi — even where the assessee is located in states such as Maharashtra, Andhra Pradesh, Kerala, Gujarat, Uttarakhand, or Himachal Pradesh. This reflects the centralised faceless appeals regime and is a consistent procedural feature across the dataset.
Revenue appeals alongside assessee appeals. Both Revenue-initiated and assessee-initiated appeals appear in this set. This indicates Section 80P(2) disputes move in both directions at the ITAT level, with neither side consistently prevailing at the first appellate stage.
Revisional jurisdiction under Section 263 as a flashpoint. At least two cases (cases 2 and 9, both engaging Section 263) involve the PCIT or CIT invoking revisional jurisdiction against assessment orders, suggesting that even where an AO allowed the Section 80P(2) deduction, revisional authorities have sought to re-examine the grant of that deduction.
Consolidation of multiple assessment years into a single order. Several proceedings in this compilation involved two or three assessment years being clubbed and disposed of by a common order — cases 1 (AY 2018-19 & 2020-21), 3 (AY 2016-17, two appeals), 8 (AY 2012-13, 2017-18 & 2018-19), 9 (AY 2018-19 & 2020-21), and 12 (AY 2012-13, 2013-14 & 2017-18) — a pattern indicating that the deduction dispute, once arising, tends to recur across successive years for the same entity.
Geographic spread and multi-bench involvement. The twelve rulings span seven ITAT benches (Pune, Vizag, Cochin, Nagpur, Rajkot, Dehradun, Chandigarh), indicating that Section 80P(2) litigation is geographically diffuse and is not concentrated in any single jurisdiction. This makes bench-specific precedent tracking an important aspect of research in this area.

How to use this compilation

This index is designed as a first-pass research tool. Each entry identifies the parties, bench, date, sections engaged, and procedural posture as extracted from the source data. Researchers should treat this compilation as a gateway to the full judgments rather than a substitute for them. Before placing reliance on any ruling listed here, the full order text should be obtained from the ITAT's official portal, indiankanoon.org, or the relevant court record system, and read in its entirety. Summary descriptions drawn from text previews may not capture all grounds raised, all issues decided, or the final operative direction of the order.

Researchers should additionally verify whether any ruling listed here has been challenged in a higher forum — specifically, whether an appeal has been filed before the relevant High Court under Section 260A, or whether a Special Leave Petition has been filed before the Supreme Court. Orders of the ITAT are not final until the limitation period for further appeal has expired or any pending higher-court proceedings have been disposed of. Similarly, it is advisable to check whether any relevant CBDT circular, instruction, or notification has been issued that may affect the legal position on Section 80P(2) for the assessment years in question.

For practitioners conducting due diligence or researching co-operative sector taxation, this compilation may be used to identify fact-pattern analogues — for instance, cases involving revisional jurisdiction under Section 263, disputes over interest income from other co-operative institutions, or the interplay between Section 80P(2) sub-clauses and the exclusion under Section 80P(4). Cross-referencing these rulings against any available coordinate bench decisions and High Court precedents on Section 80P will produce a more complete picture of the current litigation landscape.

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) Co-operative Society Deductions: 12 ITAT Rulings (2025)