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IN THE INCOME TAX APPELLATE TRIBUNAL

MUMBAI BENCH “H(SMC)”, MUMBAI

BEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER AND

SHRI ANIKESH BANERJEE, JUDICIAL MEMBER

ITA No.1661/Mum/2026

(Assessment year: 2020-21)

Sovereign Co-Op HSG Soc. vs ITO Ward 41(1)(5), Mumbai

Ltd. Kautilya Bhavan, Mumbai

Incorp Advisory Services P.

Ltd., 2^nd Floor Geeta Building,

Sion Circle, Next to HP Petrol

Pump, Sion (East),Mumbai-

400022

PAN:AABAP6171B

APPELLANT RESPONDENT

Assessee by : Shri Margav Shukla

Revenue by : Shri Pravin Salunkhe (SR.DR)

Date of hearing : 15/04/2026

Date of pronouncement : 21/04/2026

O R D E R

Per:Anikesh Banerjee (JM):

The instant appeal of the assessee filed against the order of the NFAC, Delhi

[for brevity the “Ld. CIT(A)”], order passed under section 250 of the Income Tax

Act 1961 (for brevity ‘the Act’) for Assessment Year 2020-21, date of order

19.12.2025. The impugned order emanated from the order of the Assessment

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ITA No.1661/Mum/2026

Sovereign Co-Op Soc. Ltd.

Unit Income Tax Department (for brevity the ‘Ld. AO’) order passed under section

143(3) r.w.s. 144B of the Act date of order 09.09.2022.

2. The brief facts of the case are that the assessee is a cooperative society and

registered under the relevant Cooperative Societies Act. For the impugned

assessment year the assessee filed the return by declaring total income

Rs.1,76,600, after claiming deduction under Chapter-VIA amounting to

Rs.25,31,987/-. The Ld. AO had selected the assessee’s case for scrutiny and

issued the notice u/sec. 143(2) of the Act. During assessment proceeding the Ld.

AO found that the assessee had claimed the deduction amount of Rs.24,81,987/-

u/sec. 80P(2)(d) in respect of interest received from the investment from

Cooperative Banks and also the assessee claimed standard deduction of

Rs.50,000/- u/sec. 80P(2)(c)(ii) of the Act. The Ld. AO rejected the assessee’s claim

and made the addition amount of Rs.25,77,239/- after treating the income from

other sources. Being aggrieved assesse filed an appeal before the Ld. CIT(A). The

CIT(A) rejected the assessee’s appeal. Being aggrieved assessee filed an appeal

before us.

3. The Ld. AR argued and filed a paper book comprising page 1 to 124 which

has been placed on record. Related to argument for claiming deduction u/sec

80P(2)(d), the Ld. AO contended that the assessee had earned interest from

investment from Cooperative Bank. The identical issue was adjudicated by the Ld.

CIT(A) for A.Y. 2017-18 and passed the appellate order dated 10.11.2025. In AY

2017-18 the Ld. CIT(A) had recognized the assessee’s claim of deduction u/sec

80P(2)(d) as a result the assessee’s appeal was allowed related to this ground. So,

the Ld. AR prayed for allowing the appeal of the assessee related to same interest

earned from same investment in this impugned assessment year.

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Sovereign Co-Op Soc. Ltd.

4. On the other hand, the Ld. DR vehemently argued and stated that in section

80P(4) is restricted to deduction of interest from co-operative banks under

section 80P(2)(d) of the Act. Section 80P(4) does not permit the deduction of

interest of co-operative banks. The Ld.DR fully relied on the orders of the revenue

authorities.

5. We heard the rival submissions and considered the documents available on

record. The only issue as agitated by the assessee society related to interest and

dividend from co-operative banks which is claimed as deduction under section

80P(2)(d) of the Act. Ld. AR contended that the Ld. CIT(A) adjudicated the

identical issue for AY 2017-18 in assessee’s own appeal and allowed the claim of

deduction u/s 80P(2)(d). Whereas in the instant case, the assessee has received

interest only from Co operative Banks. Section 80P(2)(d) provides for deduction of

interest received by a Co-operative Society from another Co-operative Society. A

Co-operative Society being a Co-operative Society fits into the permissible

provisions of the deductions. Thus the case referred by the Ld. CIT(A) in his

judgment is not applicable or relatable to the