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TMI Blog2019 (8) TMI 1131X X X X Extracts X X X X X X X X Extracts X X X X ..... ciety - scope of CBDT Circular (No.6/2010 dated 20.9.2010) - Section 22 of the Regional Rural Banks Act, 1976 - HELD THAT:- CBDT reasoning appears to be that Section 80P was amended w.e.f. 1.4.2007 introducing specifically that the benefit of exemption would not apply to any cooperative bank other than Primary Agricultural Credit Society or a Primary Cooperative Agricultural and Rural Development ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cieties and all the contingent consequences that flow from it - no substantial question of law involved. X X X X Extracts X X X X X X X X Extracts X X X X ..... the benefit under Section 80P(2) of the Act of 1961. Section 22 of the Regional Rural Banks Act, 1976 states as follows: "22. Regional Rural Bank to be deemed to be a cooperative society for purpose of the Income Tax Act, 1961- For the purpose of the Income Tax Act, 1961 (43 of 1961), or any other enactment for the time being in force relating to any tax on income, profits, or gains, a Regional ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he purposes of Income Tax Act. In the absence of non-obstante clause, the mere fact that a restrictive condition was imposed in relation to a Cooperative Bank for regulating the benefit of Section 80P, does not in any manner, alter the pre-existing situation. By virtue of Section 22, Regional Rural Banks continue to be deemed Cooperative Societies and all the contingent consequences that flow fr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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