IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE MURALI PURUSHOTHAMAN TUESDAY, THE 25^TH DAY OF JUNE 2024 / 4TH ASHADHA, 1946 WP(C) NO. 21866 OF 2024 PETITIONER:

THE MEENACHIL TALUK COOPERATIVE EMPLOYEES COOPERATIVE SOCIETY LIMITED, KURISUPALLY JUNCTION, PALA P.O.

KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY, SRI. BIJUKUMAR. G, PIN - 686575 BY ADVS.

G.MINI(1748)

A.KUMAR (SR.) P.J.ANILKUMAR P.S.SREE PRASAD BALASUBRAMANIAM R.

RESPONDENTS:

1 COMMISSIONER OF INCOME TAX (APPEALS)

INCOME TAX DEPARTMENT, NATIONAL FACELESS APPEAL CENTRE (NFAC), MINISTRY OF FINANCE, GOVT. OF INDIA, NEW DELHI, PIN - 110001

2 INCOME TAX OFFICER, INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI ROAD, WARD 3, KOTTAYAM, PIN – 686001 R BY SR.JOSE JOSEPH SR.SC R BY SRI.CYRIAC TOM, GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 25.06.2024, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

'CR'

JUDGMENT

The petitioner, a Co-operative Society, is an assessee under the Income Tax Act, 1961 (hereinafter referred to as 'the Act', for short). The petitioner filed its return of income for the assessment year 2017-18 and claimed deduction under Section 80P of the Act. The 2^nd respondent,