JUDGMENT

R.F. Nariman, J.

I.A. Nos. 192273 and 192277 of 2019 are allowed. Leave granted in the Special Leave Petition arising out of Diary No. 31268 of 2019.

2. These appeals have been filed by co-operative societies who have been registered as 'primary agricultural credit societies', together with one 'multi-State co-operative society', and raise important questions as to deductions that can be claimed under section 80P(2)(a) (i) of the Income-Tax Act, 1961 ("IT Act"); and in particular, whether these assessees are entitled to such deductions after the introduction of section 80P(4) of the IT Act by section 19 of the Finance Act, 2006 (21 of 2006) with effect from 01.04.2007. It may be stated at the outset that all these assessees, who are stated to be providing credit facilities to their members for agricultural and allied purposes, have been classified as primary agricultural credit societies by the Registrar of Cooperative Societies under the Kerala Co-operative Societies Act, 1969 ("Kerala Act"), and were claiming a deduction under section 80P(2)(a) (i) of the IT Act, which