virtue of section 80P(4) of the Act, the
assessee's income claimed as exempt u/s. 80P(2 ... cooperative banks. Section
80P(4) does not define the word "cooperative society". The existing
sub-section 80P(2)(a)(i) shall be applicable
statute book sub-section
(4) in Section 80P of the Act was to exclude the applicability of
Section 80P of the Act altogether ... operative Bank. This exclusion
by Section 80P(4) of the Act even though without any
amendment in Section 80P(2
Section 81 was omitted
and its provisions re-enacted as Section 80P of the 1961 Act.
The relevant extract of Section 80P ... purposes, reads:
"Amendment of section 80P . In
section 80P of the Income-tax Act, in
sub-section (2), in clause (a), for sub-
clause
deduction under
section 80P . He also brought to our notice the other provisions in
section 80P , such as in section 80P(2)(b) , where ... outside section 80P(4) should not, in any manner,
cut down the beneficial provision contained in section 80P(1) and (2),
as section 80P
mentioned that in Clause (b) of Sub-section (2) of Section 80P, reference has been made to primary society as well as federated co-operative ... Section 81(i)(c), as it stood prior to its substitution by Section 80P. The said provision was in pari materia to Section 80P(2
take note that under Sub-section (3) of Section 80P the deduction available under Sub-section (1) of Section 80P shall be allowed after reducing ... special reference to Section 80B(5) read with Section 80AB of the Act is the net figure.
28. Section 80P(2
Section 80P .
6. Sub-section (1) of Section 80P entitles a Co-operative
Society to deduct the sums specified in sub-section (2) from ... gross total income, while computing the total income.
Sub-section (2) of Section 80P reads as follows:
(2) The sums referred to in sub-section
Income-tax Act. Section 80P grants deduction in respect of certain categories of income of a co-operative society. Section 80P(1) provides that ... sums specified in sub-section (2) shall be deducted in computing the total income of the assessee. Sub-section (2)(a)(iii) stipulates that
Section
80P(4) of the Act.
8. However, in the aforesaid decision, on the related issue of
whether deduction u/s 80P(2)(d) should ... provisions of that section, the sums specified
in sub-section (2) in computing the total income of the
assessee. Sub-section (2)(d) refers
section (4) of Sec. 80P , the
assessee would no more be entitled for claim of deduction under Sec.
80P(2)(d) of the interest income ... insertion of Sub-section (4) of Sec. 80P would no more be
entitled for claim of deduction under Sec. 80P of the Act, but however
