Co-operative · Soi:ieties - Income Tax Act, 196I. - s. 80P(2)(a)(i) ·:- Deduction under~When. not available ~Appellant  society claiming to be a co-operative society, sought deduction in respect of its income -Assessing Officer held that deduction u/s. 80P was not admissible to the appellant as the benefit of deduction was admissible to those co-operative societies that carry on business of banking or providing credit facilities to its members, however, the appellant was carrying on the banking business for public at large and its operation was not confined to its members only - Appeal there against rejected by CIT (A) upholding the order of Assessing ·Officer - Further appeal to ITAT and High Court, dismissed - On appeal, held: Appellant was catering to two distinct categories of people, the first was that of 'resident members' and the other  category was of 'nominal members' who were making deposits with the assessee for the purpose of obtaining loans, etc. and were not members in real sense - Thus,. the activity of the appellant was that of finance business and cannot be termed as co-operative society - Further, the appellant was engaged in the activity of granting loans to general public as well - Therefore, the appellant cannot be treated as a co-operative society meant only for its members and . providing credit facilities to its members - Such a society cannot claim the benefit of s. 80P - Mutually Aided Co-operative Societies Act, I995 - Banking.