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3. Mr. S. V. Subramaniam, learned counsel for the assessee, submitted that when the assessee sold goods such as textiles, toilet articles and other provisions to its members on credit, it must be held that the society was extending credit facilities to its members. Since sales on credit must be regarded as providing credit facilities, the learned counsel submitted that the society itself must be regarded as one which has provided credit facilities to its members.

4. We do not accept this contention as well founded. Section 80P(2)(a)(i) of the Act refers to a co-operative society engaged in carrying on the business of banking or providing credit facilities to its members. It is not suggested in this case that the assessee carries on the business of banking. All that is urged is that it provides credit facilities to its members. It may be that in a broad sense there is a provision of credit in every transaction of sale on credit. But, it cannot be said that a co-operative society which is engaged in selling or distribution consumer goods or other goods to its members for deferred consideration can be said to be extending credit facilities merely because it does not insist on cash payment but prefers to collect the consideration after a time. In the literature of law relating to co-operative societies there is a well-merited distinction between credit societies, on the one hand, and consumer societies, on the other, not to speak of societies engaged in various productive activities. When the section refers to a co-operative society engaged in providing credit facilities to its members it really refers to a credit society, whose primary object is the provision of loans or other credit facilities to its members. It does not include any society whose primary object is something other than the provision of loans or other credit facilities, such as a consumer co-operative society.