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11. In our considered view, once the claimant assessee falls outside the ambit of explanation (a) to section 80P(4) of the Act then denial of 80P(2) deduction would be contra-legem. This find fortified in case of 'PCIT Vs Annasaheb Patil Mathadi Kamgar Sahakari Pathpedi Ltd.' [2023, 454 ITR 117 (SC)], where the assessee was a cooperative credit society engaged in the business of providing credit facilities to its members. The assessee claimed deduction u/s 80P(2) of the Act, but the Assessing Officer Goa Bagayatdar Sahakari Vikri Saunstha Maryadit Vs ITO, Goa ITA Nos.022 to 024/PAN/2025 disallowed the deduction holding that the assessee is a cooperative bank and hence not eligible to claim deduction as per Section 80P(4) of the Act. The first and second appellate authority and the Hon'ble Jurisdictional High Court held in favour of assessee holding that assessee is a co-operative society and not a cooperative bank, hence eligible for deduction u/s 80P(2) of the Act.