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2018 (3) TMI 373 - AT - Income TaxDeduction u/s. 80P(2) - claim denied for the reason that the assessee cannot be considered as Primary Agricultural Credit Society - Held that:- As decided in Nannambra Service Co-operative Bank Ltd. [2018 (2) TMI 866 - ITAT COCHIN] Reserve Bank of India, which is the competent authority as per the Banking Regulation Act, treats assessee society and similar societies as only “Primary Agricultural Credit Society” not falling within the ambit of Banking Regulation Act. The Reserve Bank of India has given letters to the societies similar to assessee stating that they are Primary Agricultural Credit Societies and therefore in terms of section 3 of the Banking Regulation Act are not entitled for banking license. The assessee had extended credit facilities only to the members. The Revenue does not have a case that such credit facilities are extended to the outsiders. Therefore the income generated in the instant case is only out of the transaction with the members. Deduction u/s. 80P is allowed only for the said income. The assessee had claimed deduction u/s. 80P only in respect of net income which is derived by extending credit facilities to the members. - Decided against revenue
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