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b) To receive deposit from members and others after getting approval from NABARD /RBI.
c) To fulfil the objects, society shall become member of the Rajasthan State Cooperative Land Development Bank and shall follow the policies laid by Rajasthan State Cooperative Land Development Bank.' In the light of the foregoing, we find nothing in its object clause to suggest that its primary object is providing financial accommodation to its members for agricultural purposes or for purposes connected with agricultural activities (including marketing of crops), as stipulated per section 5 (cciv) of the B.R. Act, so as to qualify as a `primary agricultural credit society' (PACS). The only object which enables it to provide financial accommodation is its object clause 2(a). The same only specifies the assets on the security of which the assesse-society may provide finance to its members. The securitization of a loan or advance is a different aspect of the matter, and completely different from the Kekri Sahakari Bhumi Vikas Bank Ltd. vs. ITO, Ward- 2, Beawar purpose or the activity for which finance is being provided, and which is being thus financed. The assessee claims the decision in the case of Madras Auto Rickshaw Drivers' Co-operative Society vs. CIT (supra) as not applicable thereto, as while in that case the object clause was the promotion of economic interests of its members by purchasing auto rickshaw vehicles and selling the same to them on hire purchase terms, and not providing credit facilities to its members, in the present case, it is expressly so. We agree. However, that by itself is not sufficient, and it is to be in addition expressed to be for agricultural purposes or for purposes connected with agricultural activities, and on which its object clause, as also the assessee, is silent. So however, we are not inclined to oust the assessee's case on that basis. This is as there is another window available to it in law, i.e., where the principal business is financing the agricultural or connected activities of its members (section 5 (cciv) read with section 56(c) of the B.R. Act). Though it could be argued that such principal business could be taken the cognizance of where it finds reflection in the assessee's charter/object clause, we do not think it to be so. This is as such an interpretation would render the words 'principal business' occurring in the provision as superfluous and otiose, while it is well settled that each and every word of the statue has to be given its due meaning and, thus, effect. As such, though not expressly through its object clause, if it could yet be shown by the assessee that its principal business consists of providing financial accommodation to its members for agricultural purposes or for purposes connected with agricultural activities (including marketing of crops), it would in law qualify to be a PACS and, thus, exempt u/s.

As per Explanation to Section 80P(4), the definition of 'primary agricultural credit society, is to be take as per Part-V of Banking Regulation Act, 1949. The same has been reproduced in the order of Hon'ble ITAT on page 7 as under:-

(cciv) "primary agricultural credit society" means a co-operative society,--
(1) the primary object or principal business of which is to provide financial accommodation to its members for agricultural purposes or for purposes connected with agricultural activities (including the marketing of crops); and (2) the bye-laws of which do not permit admission of any other co-operative society as a member:
Provided that this sub-clause shall not apply to the admission of a co-operative bank as a member by reason of such co-operative bank subscribing to the share capital of such co-operative society out of funds provided by the State Government for the purpose;'' From the chart of loans advanced by the assessee during the year under consideration, it is apparent that assessee's principal business was not that of providing financial accommodation to its members for agricultural purposes or purposes connected with agricultural activities as per the definition of primary agricultural activity given in Part-V of Banking Regulation Act, 1949. As such, the assessee cannot be considered as primary agricultural credit society. Further, assessee is not a 'primary cooperative agricultural and rural development bank' as already noted in the order of the ITAT dated 23-03-2014 in para 4.4 of the order.