[2025:RJ-JP:44486-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Income Tax Appeal No. 89/2025 1. The Principal Commissioner Of Income Tax, Aayakar Bhawan Udaipur Rajasthan Subcity Centre, Savina, Udaipur-313001(Raj.). ----Appellants Versus Shri Hitkari Vidyalaya Sahkari Shiksha Samiti Limited, Kota ----Respondent For Appellant(s) : Mr. Shantanu Sharma with Mr. Parth Vashisth For Respondent(s) : HON'BLE THE ACTING CHIEF JUSTICE MR. SANJEEV PRAKASH SHARMA HON'BLE MR. JUSTICE BALJINDER SINGH SANDHU Order 06/11/2025 1. The issue raised in the present appeal stands covered by the judgment passed in the case of PCIT Ajmer V/s M/s Bhilwara Zila Dugdh Utpadak Sahakari Sangh Ltd. (D.B. Income Tax Appeal No.2/2019) dated 13.08.2019, where for the assessment year 2014-2015 the issue was decided, holding that the CBDT Circular No.06/2010 dated 20.09.2010 would not be applicable as Section 22 of the Regional Rural Banks Act, 1976 deems RRBs as Co-operative Societies for the purpose of Income Tax Act, 1961 and in the absence of non-obstante clause, the restrictive condition imposed with regard to regulation of benefit of Section 80P of the Act of 1961 would not change the pre- existing situation and they would continue to remain as [2025:RJ-JP:44486-DB] (2 of 2) [ITA-89/2025] Co-operative Societies and the benefit flowing thereto would be available to RRBs. 2. The order passed on 13.08.2019, therefore, would apply mutatis mutandis to the present case. 3. The appeal is, accordingly, dismissed. Pending application(s) also stand dismissed. (BALJINDER SINGH SANDHU),J (SANJEEV PRAKASH SHARMA),ACTING CJ RAHUL MIRKHANI/32