As per case facts, Sikkim State Cooperative Supply and Marketing Federation Limited (SIMFED), a non-banking cooperative society, earned interest from investments in cooperative banks. The Assessing Officer initially disallowed the ... deduction for this interest income. While the Commissioner of Income Tax (Appeal) allowed it, the Income Tax Appellate Tribunal subsequently reversed this, disallowing the deduction due to an alleged misinterpretation of Section 80P(4) of the Income Tax Act, 1961, and reliance on certain judgments. The current appeal challenges the Tribunal's decision. The question arose whether the Tribunal misinterpreted Section 80P(4) by applying it to a non-bank cooperative society, thereby incorrectly denying Section 80P(2)(d) deductions for interest from cooperative banks, and if the Tribunal correctly applied the 'Totgars' Cooperative Sale Society Ltd.' ratio despite factual and statutory differences. Finally, the High Court held that the Tribunal indeed misinterpreted Section 80P(4), which specifically applies to cooperative banks (with exceptions), not non-banking cooperative societies like SIMFED. The Court also found that the 'Totgars' Cooperative Sale Society Ltd.' judgment was not applicable as the facts and relevant statutory provisions, particularly concerning deductions under Section 80P(2)(d) versus 80P(2)(a)(i), were materially different. Consequently, SIMFED is entitled to claim the deduction under Section 80P(2)(d) of the Income Tax Act, 1961.