COMMISSIONER OF INCOME TAXTAMIL NADU-V, MADRAS vs KOTAGIRI INDUSTRIAL CO-OPERATIVETEA FACTORY LTD., KOTAGIRI

The Supreme Court upheld the Madras High Court's decision that deductions under Section 80-P of the Income Tax Act, 1961 should be allowed before setting off unabsorbed losses from previous years. The Court affirmed that as long as the gross total income of a co-operative society includes income from activities specified in Section 80-P(2), the deduction is permissible. The Court rejected the Revenue's argument that losses should be set off first, thereby affirming the High Court's interpretation of the statute.