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2022 (6) TMI 1009 - ITAT CHENNAIDenial of claim of deduction u/s.80P(2)(a)(i) - assessee is a primary agricultural credit co-operative society - HELD THAT:- Chennai Bench of ITAT in the case of TN Co-operative State Agricultural & Rural Development [2022 (6) TMI 770 - ITAT CHENNAI] and this issue has been dealt with after considering the recent decision of Hon’ble Supreme Court in the case of The Mavilayi Service Co-operative Bank Ltd [2021 (1) TMI 488 - SUPREME COURT] Admittedly, the assessee is a primary agricultural credit co-operative society and is governed by Tamil Nadu Co-operative Societies Act and it is carrying out its co-operative business with its members, the claim of deduction u/s.80P(2)(a)(i) of the Act cannot be denied. Hence, we reverse the orders of lower authorities and allow this issue of all five appeals of assessee. TDS u/s 194A - Addition invoking the provisions of section 40(a)(ia) - HELD THAT:- As the issue is covered by the decision of Hon’ble Madras High Court in the case of Coimbatore District Central Co-operative Bank Ltd. [2016 (1) TMI 370 - MADRAS HIGH COURT], the amended provision of section 194A w.e.f. 01.06.2015, which is held as prospective, will not apply to the present case because before us the assessment year is 2009-10. Hence, this issue of assessee’s appeal is allowed.
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