This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings pronounced between September 2024 and May 2026, each engaging Section 80P(4) and/or Section 80P(2)(d) of the Income Tax Act, 1961 in the context of deduction claims by co-operative societies, co-operative banks, and allied entities. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers tracking the evolving jurisprudence on co-operative sector deductions across multiple ITAT benches — Lucknow, Pune, Amritsar, Indore, Cochin, Surat, Nagpur, and Rajkot.

Research index only. This page is a structured case-law reference tool, not legal or tax advice. Always verify against the full judgment text and check for subsequent stays, appeals, or reversals before relying on any ruling listed here.

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. Section 80P(2) enumerates the categories of income eligible for the deduction, including — under sub-clause (d) — income by way of interest or dividends derived from investments with other co-operative societies. Section 80P(4), inserted by the Finance Act, 2006 with effect from 1 April 2007, expressly carves out co-operative banks (other than a primary agricultural credit society or a primary co-operative agricultural and rural development bank) from the benefit of Section 80P, by providing that the section shall not apply to any co-operative bank. The interplay between the general deduction provisions under Section 80P(2) and the exclusionary operation of Section 80P(4) — particularly the question of whether a given entity qualifies as a "co-operative bank" for the purposes of Section 80P(4) — forms the central contested ground across all rulings in this compilation.

The 12 rulings

1. Bhojipura Ganna Samiti vs Assessment Unit, Income Tax

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 8 May 2026
Sections engaged: 80P(2)(d), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee, a co-operative society, against orders passed by the National Faceless Appeal Centre, Delhi for Assessment Years 2018-19 and 2020-21 (ITA Nos. 812 & 813/LKW/2025). Per the source preview, the assessee had declared Nil income and claimed a deduction under Section 80P, and the case was selected for Limited Scrutiny to examine the claim of deduction under Chapter VI-A; the Assessing Officer raised observations based on the Balance Sheet and Profit & Loss Account during assessment proceedings.

2. Kai Fakira Jairam Patil Sahakari vs ITO, Ward-1, Dhule, Dhule

Bench: Income Tax Appellate Tribunal - Pune
Date: 17 April 2026
Sections engaged: 80P(4), 148A
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 3110/PUN/2025) was directed against the order dated 06.10.2025 passed by the CIT(A)/NFAC for Assessment Year 2016-17. Per the source preview, the assessee is a primary credit cooperative society engaged in providing credit facilities and accepting deposits; it had filed its original return of income declaring Nil income, and reassessment proceedings were initiated on the basis of information regarding cash deposits of Rs. 9,40,86,720/- in the assessee's bank account that were reportedly not reflected in the return of income for the year under consideration.

3. The Tibba Cooperative Agriculture vs ITO Ward Kapurthala, Kapurthala

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 9 April 2026
Sections engaged: 80P(2)(d), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: Both appeals (I.T.A. Nos. 520 & 521/Asr/2024) were filed against orders of the CIT(A)/NFAC, Delhi both dated 13.08.2024 for Assessment Years 2018-19 and 2020-21. Per the source preview, the assessed income was computed at Rs. 64,62,515/- after additions on account of disallowance of interest income on deposits and dividend income, against the return of income declaring Nil income; the substantive dispute relates to the deduction claim and the disallowances made thereunder.

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: 80P(2)(d), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: Five appeals were filed by the assessee covering multiple assessment years including 2015-16, 2017-18, and 2018-19, challenging orders of CIT(A)/NFAC passed in 2024. Per the source preview, the assessment orders for various years had been passed by the National Faceless Assessment Centre and by DCIT/ACIT-1(1), Bhopal under different provisions; the appeals were heard together given overlapping facts and issues.

5. Income Tax Officer Ward-2, Ahmednagar vs Kanifnath Grmain Bigar Sheti

Bench: Income Tax Appellate Tribunal - Pune
Date: 21 January 2026
Sections engaged: 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: These were Revenue appeals (ITA Nos. 2270 & 2271/PUN/2025) for Assessment Year 2018-19, filed against the order of the CIT(A)/NFAC which had allowed the quantum appeal in favour of the assessee. Per the source preview, the assessment order had recorded interest income from multiple co-operative banks totalling Rs. 1,75,17,397/-, and the Revenue challenged the CIT(A)/NFAC's decision without, per the Revenue's own ground, considering the merits of the case.

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

Bench: Income Tax Appellate Tribunal - Cochin
Date: 27 October 2025
Sections engaged: 80P(2)(a), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals (ITA No. 556 & 569/COCH/2025) were preferred by the assessee pertaining to Assessment Year 2016-2017, both challenging the order dated 27/09/[2025] passed at the first-appeal stage. Per the source preview, the matter arose from proceedings before the Income Tax Officer, Ward 2(1), Thrissur and was heard at the ITAT Cochin "DB" Bench; the substantive dispute involves the assessee's deduction claim under the applicable sub-section of Section 80P and the applicability of the Section 80P(4) exclusion.

7. DCIT, Circle-2(1)(1), Surat, Surat vs Bardoli Vibhag Gram Vikas Co Op Credit

Bench: Income Tax Appellate Tribunal - Surat
Date: 22 August 2025
Sections engaged: 80P(2)(d), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: Four Revenue appeals (ITA Nos. 314 to 317/SRT/2025) covering Assessment Years 2017-18, 2018-19, 2020-21, and 2022-23 emanated from CIT(A)/NFAC orders dated 28.01.2025. Per the source preview, the cases were heard together on consent of both parties and a common order was passed given that the facts across the four assessment years were the same; the appeals were filed by the DCIT, Circle-2(1)(1), Surat against the first-appellate orders passed in favour of the assessee society.

8. Jai Kondeshwar Nagari Sahakari vs Income Tax Officer, Ward 3, Amravati

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 24 June 2025
Sections engaged: 80P(2)(d), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 275/NAG/2025) was filed by the assessee against the order dated 07/01/2025 passed by the ADDL/JCIT(A)-12, Delhi for Assessment Year 2022-23. Per the source preview, a delay of 26 days in filing the appeal was condoned upon consideration of the reasons and affidavit filed by the assessee; the CPC/AO had denied the deduction claimed by the assessee vide intimation/order dated 16/01/2023, and the assessee challenged that order through the first-appellate and then ITAT route.

9. Amalsad Vibhag Vivish Karyakari vs PCIT, Valsad

Bench: Income Tax Appellate Tribunal - Surat
Date: 3 February 2025
Sections engaged: 263, 80P(4), 57(iii)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 491/SRT/2024) challenged the order passed by the Principal Commissioner of Income Tax, Valsad under Section 263 dated 20.03.2024 for Assessment Year 2018-19, which in turn arose out of an assessment order passed by the National e-Assessment Centre. Per the source preview, this is a revision proceeding under Section 263 initiated by the PCIT against the assessment order, and the assessee challenged the correctness of the revisionary order before the ITAT Surat Bench.

10. Karikunnam Service Co-Operative Bank vs ITO, Ward-1 & Tps, Thodupuzha

Bench: Income Tax Appellate Tribunal - Cochin
Date: 17 December 2024
Sections engaged: 80P, 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 364/Coch/2024) was filed by the assessee challenging the NFAC, Delhi order dated 27/02/2024 in respect of Assessment Year 2017-18. Per the source preview, the assessee is a co-operative society registered under the Kerala Co-operative Society Act, 1969; it had filed its return of income on 17/10/2017 claiming a deduction of Rs. 3,05,49,081/- under Section 80P, the case was selected for scrutiny under CASS, and the Assessing Officer denied the deduction claim, prompting the assessee's appeal.

11. M/S Poyiloor Service Co-Op Bank vs ITO Ward 2, Kannur

Bench: Income Tax Appellate Tribunal - Cochin
Date: 7 November 2024
Sections engaged: 80P(4), 80P(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 151/Coch/2023) pertained to Assessment Year 2014-15. Per the source preview, both the lower authorities had disallowed the assessee's deduction under Section 80P(4), and the Revenue sought to fortify the disallowance on the ground that the assessee is in fact a co-operative bank as per the decision of the jurisdictional High Court in Pr. CIT v. Mavilayi Service Co-operative Bank Ltd. [2019] 414 ITR 67 (Ker) (FB); the ITAT considered the threshold question of whether the assessee qualifies as a co-operative bank for the purpose of Section 80P(4).

12. Deputy Commissioner Of Income Tax vs Rajkot Lodhikasahakari Kharid Vechan

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 30 September 2024
Sections engaged: 80P(2)(d), 80P(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed I.T.A. No. 370/RJT/2023 and the assessee filed Cross Objection No. 01/RJT/2024, both pertaining to Assessment Year 2020-21. Per the source preview, the variation between the return income and the computed income was Rs. 6,94,69,140/-, representing the disallowance of the deduction claimed under Section 80P(2)(d) for interest income; the issues before the Tribunal included matters relating to investments, advances, loans, unsecured loans, and deduction from total income under Chapter VI-A.

Patterns across these 12 rulings

Section 80P(4) exclusion as a recurring battleground. Across the majority of cases in this compilation, the central contested issue is whether the assessee entity falls within the exclusionary scope of Section 80P(4) — i.e., whether it constitutes a "co-operative bank" disentitled to the Section 80P deduction — or whether it retains eligibility as a primary agricultural credit society or a primary co-operative credit society serving its members.
Section 80P(2)(d) interest-income disallowances. A distinct and recurring sub-theme involves the disallowance of interest income earned by co-operative societies on deposits or investments held with other co-operative societies or banks. Cases 1, 3, 4, 7, 8, and 12 all engage Section 80P(2)(d) alongside Section 80P(4), indicating that Revenue authorities frequently contest both the eligibility of the entity and the eligibility of the specific income stream.
Multi-year bundled appeals and common orders. Several rulings in this set — cases 1, 3, 4, and 7 — involve multiple assessment years heard together and disposed of through a single common order. This reflects a systemic pattern where the same deduction dispute recurs across consecutive years for the same assessee, with the facts and legal issues being substantially identical across those years.
Faceless assessment and NFAC-routed first appeals. Across virtually all cases, the first-appellate order challenged before the ITAT was passed by the National Faceless Appeal Centre (NFAC), Delhi. This underscores that the faceless regime has become the standard procedural pathway for Section 80P deduction disputes, and ITAT proceedings are now the first forum of oral hearing for these matters.
Revenue as appellant in several proceedings. Cases 5, 7, and 12 feature the Revenue (ITO, DCIT, or the department) as the appellant before the ITAT, indicating that CIT(A)/NFAC had decided certain matters in favour of the assessee at the first-appellate stage, with the department then seeking reversal before the Tribunal. This bidirectional litigation pattern suggests persistent uncertainty at both the assessment and first-appellate levels regarding the correct application of Section 80P(4).

How to use this compilation

This index is designed as a starting point for legal research, not as a substitute for reading the full judgment text. Each ruling listed above should be independently verified against the complete order as published on the Income Tax Appellate Tribunal's official website or on indiankanoon.org. Researchers should confirm that no appeal, stay, or reversal is pending before the relevant High Court or the Supreme Court in respect of any ruling cited here. The outcome field for all twelve rulings reads "Outcome not specified in source," which means the dispositive direction of the order — whether the appeal was allowed, dismissed, or partly allowed — could not be conclusively extracted from the available preview text; researchers must access the full order to determine the operative holding.

When using this compilation for advisory or litigation purposes, researchers should also check for any CBDT circulars, instructions, or administrative guidance issued in connection with Section 80P(4) that may govern the departmental position in pending assessments or appeals. The classification of a co-operative entity as a "co-operative bank" versus a "primary agricultural credit society" or "primary co-operative credit society" is a factual and legal determination that turns on the specific registration, activities, and regulatory framework applicable to each assessee; no generalisation across the cases in this index should be made without examining the full facts of the matter at hand.

Researchers working on Assessment Year-specific questions should note that several rulings in this compilation span multiple assessment years within a single common order; the legal analysis applicable to one year in such an order may not be identical to that applicable to another year if the facts or the applicable statutory provisions changed in the intervening period.

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(4) & 80P(2)(d): 12 ITAT Rulings on Co-operative Society Deductions (2024–2026)