TMI Blog2019 (8) TMI 1131X X X X Extracts X X X X X X X X Extracts X X X X ..... HAT:- CBDT reasoning appears to be that Section 80P was amended w.e.f. 1.4.2007 introducing specifically that the benefit of exemption would not apply to any cooperative bank other than Primary Agricultural Credit Society or a Primary Cooperative Agricultural and Rural Development Bank. The circular then stated that in the light of this inclusion to Section 80P by way of introduction of Section ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - D.B. Income Tax Appeal No. 2/2019 - - - Dated:- 13-8-2019 - The Chief Justice S. Ravindra Bhat And Mr. Justice Dinesh Mehta For the Appellant(s) : Mr. KK Bissa For the Respondent(s) : Mr. Sanjeev Johari with Mr. Lalit Parihar JUDGMENT The revenue urges that the grant of exemption under Section 80P(2) of the Incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions and more specifically Regional Rural Banks do not qualify for the benefit under Section 80P(2) of the Act of 1961. Section 22 of the Regional Rural Banks Act, 1976 states as follows: 22. Regional Rural Bank to be deemed to be a cooperative society for purpose of the Income Tax Act, 1961- For the purpose of the Income Tax Act, 1961 (43 of 1961), or any other enactment for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l Rural Banks (of which description Baroda Rajasthan Regional Rural Banks answer to) as Cooperative Societies for the purposes of Income Tax Act. In the absence of non-obstante clause, the mere fact that a restrictive condition was imposed in relation to a Cooperative Bank for regulating the benefit of Section 80P, does not in any manner, alter the pre-existing situation. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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