Before the ITAT, the sole issue was whether interest earned by a co-operative society on term deposits with a State Co-operative Bank qualified for deduction under Section 80P(2)(d). It further observed that Section 80P(4) applies only where the claimant itself is a co-operative bank and does not deny deduction to a co-operative society receiving interest from another registered co-operative society. The Tribunal found that the assessee was a registered co-operative society and that GSCBL was also a registered co-operative society under the Goa State Co-operative Societies Act. In terms of section 10 (supra) the GSCBL is granted registration under ‘class-3 as co­operative bank with sub class as central Bank’. GSCBL although is a co-operative bank in common parlance but not a co-operative bank strictly within the meaning assigned in Part V of BRA.