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JUDGMENT 1. The assessee has come up in appeal invoking Section 260A of the Income Tax Act, 1961 (for short the Act'), calling in question the assessment order dated 31.10.2012, Annexure 'B', the order dated 07.10.2013 of the First Appellate Authority, Annexure 'C' and order dated 17.04.2014 of the Income Tax Appellate Tribunal, Panji Branch, Panaji (for short 'Tribunal') Annexure 'A', declining to extend the benefit of deduction under Section 80P(2)(a)(i) of the Act. 2. The crux of the matter lies in the registration of the appellant Co-operative Credit Society under the Karnataka Co-operative Societies Act, 1959, (for short 'KCS Act') and the core question for decision making is: 'Whether the appellant-a Multipurpose Co-operative Credit Society, falling within the definition of the term "Primary Agricultural Credit Co-operative Society" under Section 2(h-2) of the 'KCS Act', is entitled to the benefit of deduction in respect of its income under Section 80P(2)(a)(i) of the Act regard being had to Section 80P(4) of the Act?' 3. The appellant a Multi-purpose Co operative Credit Society, registered under the 'KCS Act' with Registration Certificate dated 23.10.2001, filed its return for the assessment year 2010-11, declaring gross total income of Rs. 11,24,117/- and claimed the entire amount as a deduction under Section 80P(2)(a)(i) and the taxable income as NIL. 4. The Assessing Authority (ITO, Ward-1(2), Belgaum), by assessment order dated 31.10.2012, Annexure 'B', declined the deduction and assessed the income to Rs. 12,11,580/-, on the premise that the appellant is a Primary Co-operative Bank disentitled to the benefit of deduction under, Section 80P(2)(a)(i), in the light of Section 80P(4) of the 'Act'. That order when carried in first appeal before the Commissioner of Income Tax (Appeals), Belgaum, was confirmed by dismissal of the appeal by order dated 07.10.2013, Annexure 'C. The appellant preferred appeal before the Tribunal, whence by order dated 17.04.2014, Annexure 'A', the appeal was dismissed. 5. Sub-section (4) of Section 80P of the Act reads thus: '80P. Deduction in respect of income of Co-operative Societies - (1) to (3)** ** ** (4) The provisions…

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