Chapter VIII - Deductions to be Made in Computing Total Income
Section 149
Section 149: deduction for income of co-operative societies
Section 149 gives co-operative societies a set of activity-specific deductions - from a full deduction for banking and cottage-industry-type businesses, to capped deductions for other business activities, to deductions for interest/dividend income from other co-operative societies and for godown or warehouse rental income.
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Need advice on Section 149?
This article is for general information. Refer to the Income-tax Act, 2025 as amended by the Finance Act, 2026 and the Taxation and Other Laws (Amendment) Act, 2026 for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
(1) If the gross total income of an assessee, being a co-operative society, includes any income referred to in sub-section (2), the sums specified in the said sub-section shall, in accordance with and subject to the provisions of this section, be allowed as deduction in computing the total income of such assessee.
(2) The sums referred to in sub-section (1) shall be the following:— (a) in the case of a co-operative society engaged in— (i) carrying on the business of banking or providing credit facilities to its members; or(ii) a cottage industry; or (iii) the marketing of agricultural produce grown by its members; or (iv) the purchase of agricultural implements, seeds, livestock or other articles intended for agriculture for the purpose of supplying them to its members; or (v) the processing, without the aid of power, of the agricultural produce of its members; or (vi) the collective disposal of the labour of its members; or (vii) fishing or allied activities, that is to say, the catching, curing, processing, preserving, storing or marketing of fish or the purchase of materials and equipment in connection therewith for the purpose of supplying them to its members, the whole of the amount of profits and gains of business attributable to any one or more of such activities; (b) in the case of a co-operative society, being a primary society engaged in supplying milk, oilseeds, cotton seed, cattle feed, fruits, or vegetables raised or grown by its members to— (i) a federal co-operative society, being a society, engaged in the business of supplying milk, oilseeds, cotton seed, cattle feed, fruits or vegetables; or (ii) the Government or a local authority; or (iii) a Government company, as defined in section 2(45) of the Companies Act, 2013 (18 of 2013), or a corporation established by or under a Central Act or State Act or Provincial Act, engaged in supplying milk, oilseeds, cotton seed, cattle feed, fruits or vegetables, as the case may be, to the public, the whole of the amount of profits and gains of such business; (c) in the case of a co-operative society engaged in activities other than those specified in clause (a) or (b), (either independently of, or in addition to, all or any of the activities so specified), that amount of profits and gains attributable to such activities as does not exceed— (i) ₹100000, if the society is a consumers’ co-operative society; and (ii) ₹50000, in any other case; (d) in respect of any income derived by the co-operative society from its investments with any other co-operative society by way of— (i) interest; or (ii) dividends, the whole of such income; (e) in respect of any income derived by the co-operative society from the letting of godowns or warehouses for storage, processing, or facilitating the marketing of commodities, the whole of such income; (f) in the case of a co-operative society, not being— (i) a housing society; or (ii) an urban consumers’ society (being a society for the benefit of the consumers within the limits of a municipal corporation, municipality, municipal committee, notified area committee, town area, or cantonment); or (iii) a society carrying on transport business; or (iv) a society engaged in performing manufacturing operations with the aid of power, where the gross total income does not exceed ₹20000, the amount of income by way of interest on securities; any income from house property chargeable under section 20.
(3) In the case of a co-operative society as referred to in sub-section (2)(a)(vi) or (vii), provisions of sub-section (1) shall only apply when the rules and bye-laws of the society restrict the voting rights to the following classes of its members:— (i) the individuals who contribute their labour or carry on fishing or allied activities; (ii) the co-operative credit societies which provide financial assistance to the society; (iii) the State Government.
(4) The deduction under sub-section (1) in relation to the sums specified in subsection (2)(a) or (b) or (c) or sub-section (3), shall be allowed with reference to the income referred to in those sub-sections included in the gross total income after reducing the deduction under section 138, if the assessee is also entitled to such deduction.
(5) The provision of this section shall not apply to any co-operative bank which is not a primary agricultural credit society or a primary co-operative agricultural and rural development bank.
(6) For the purposes of this section,–– (a) “consumers’ co-operative society” means a society for the benefit of the consumers; (b) “primary agricultural credit society” has the same meaning as assigned to it in Part V of the Banking Regulation Act, 1949 (10 of 1949); and (c) “primary co-operative agricultural and rural development bank” means a society having an area of operation confined to a taluk, the principal object of which is to provide long-term credit for agricultural and rural development activities.
Introduction
Section 149 provides category-specific deductions for co-operative societies, including qualifying member-oriented business, certain supplies, limited other activity and specified investment or property income. The Finance Act, 2026 amended parts of this section, so the current clause must be read rather than an old summary.
Key takeaways
Co-operative-society income
An eligible co-operative society may deduct specified categories of income included in its gross total income, to the amounts and conditions listed in subsection (2).
Category controls amount
The provision distinguishes particular activities and receipts, so a society must match the income to the correct clause before claiming any full or limited deduction.
The basic rule
Where the gross total income of an assessee, being a co-operative society, includes income of a kind described below, the corresponding sum is allowed as a deduction in computing the society's total income, in accordance with and subject to the rest of this section.
Full deduction for specified core activities
For a co-operative society engaged in any one or more of the following activities, the whole of the profits and gains of business attributable to those activities is deductible:
- Carrying on the business of banking or providing credit facilities to its members
- Cottage industry
- Marketing of agricultural produce grown by its members
- Purchase of agricultural implements, seeds, livestock or other articles intended for agriculture, for supplying them to its members
- Processing, without the aid of power, of the agricultural produce of its members
- Collective disposal of the labour of its members
- Fishing or allied activities - catching, curing, processing, preserving, storing or marketing of fish, or purchasing materials and equipment for that purpose, for supplying to its members
Full deduction for primary societies supplying milk, oilseeds, cotton seed, cattle feed, fruits or vegetables
A primary co-operative society engaged in supplying milk, oilseeds, cotton seed, cattle feed, fruits, or vegetables raised or grown by its members gets a full deduction of the profits from that business, where the supply is made to: a federal co-operative society engaged in the business of supplying those items; or the Government or a local authority; or a Government company or statutory corporation engaged in supplying those items to the public.
Capped deduction for other business activities
For a co-operative society engaged in activities other than those above (whether alone or in addition to them), the amount of profits and gains attributable to those other activities is deductible only up to:
| Type of society | Cap |
|---|---|
| Consumers' co-operative society | ₹1,00,000 |
| Any other case | ₹50,000 |
Deduction for interest/dividend income and godown/warehouse rental income
The whole of any income derived by a co-operative society from its investments with any other co-operative society by way of interest or dividends is deductible.
The whole of any income derived by a co-operative society from letting godowns or warehouses for storage, processing, or facilitating the marketing of commodities is deductible.
Deduction for smaller societies' interest-on-securities and house-property income
For a co-operative society that is not a housing society, an urban consumers' society (benefiting consumers within a municipal corporation, municipality, municipal committee, notified area committee, town area or cantonment), a society carrying on transport business, or a society doing manufacturing with the aid of power, and whose gross total income does not exceed ₹20,000, the deduction also covers income by way of interest on securities and any income from house property chargeable under section 20.
Restriction on voting rights for labour/fishing societies
For a society engaged in collective disposal of labour, or fishing/allied activities, the deduction under sub-section (1) applies only when the society's rules and bye-laws restrict voting rights to: individuals who contribute their labour or carry on fishing or allied activities; co-operative credit societies that provide financial assistance to the society; and the State Government.
Interaction with Section 138
Where the assessee is also entitled to a deduction under section 138, the Section 149 deduction on the income covered by sub-section (2)(a), (b), (c) or sub-section (3) is worked out after first reducing that Section 138 deduction from the relevant income.
Who Section 149 does not apply to
This section does not apply to any co-operative bank that is not a primary agricultural credit society or a primary co-operative agricultural and rural development bank.
Key definitions
| Term | Meaning |
|---|---|
| Consumers' co-operative society | A society for the benefit of the consumers |
| Primary agricultural credit society | Has the same meaning as assigned in Part V of the Banking Regulation Act, 1949 |
| Primary co-operative agricultural and rural development bank | A society having an area of operation confined to a taluk, whose principal object is to provide long-term credit for agricultural and rural development activities |
Step-by-step flow for applying Section 149
- 1
Is the assessee a co-operative society?
- No: Section 149 does not apply.
- Yes: Go to the next step.
- 2
Is it a co-operative bank other than a primary agricultural credit society or a primary co-operative agricultural and rural development bank?
Section 149(5) excludes such co-operative banks.
- Yes: No deduction under Section 149.
- No: Go to the next step.
- 3
Split gross total income into the categories of Section 149(2)
Clause (a) core activities (whole profits); clause (b) primary societies supplying milk, oilseeds, cotton seed, cattle feed, fruits or vegetables to the listed buyers (whole profits); clause (c) other activities (capped); clause (d) interest or dividends from investments with other co-operative societies (whole); clause (e) letting of godowns or warehouses (whole); clause (f) interest on securities and house property income for small societies.
- 4
Does the society undertake collective disposal of labour or fishing and allied activities?
- Yes: Check that the rules and bye-laws restrict voting rights to the classes listed in Section 149(3) before claiming.
- No: Go to the next step.
- 5
Apply the caps and the Section 138 ordering rule
Clause (c) is capped at ₹1,00,000 for a consumers' co-operative society and ₹50,000 in any other case. Clause (f) is available only where gross total income does not exceed ₹20,000 and the society is not a housing, urban consumers', transport or power-aided manufacturing society. Where Section 138 also applies, Section 149(4) requires the relevant income to be reduced by that deduction first.
Practical checklist
Do
- Classify the society and each income stream under the exact subsection (2) category.
- For credit or banking activities, check the primary-society exceptions and amended definitions before claiming.
Avoid
- Do not apply one deduction percentage to every co-operative income category.
- Do not assume an ordinary co-operative bank qualifies under the primary agricultural credit exception.
Illustrative example
Worked example: a multi-activity agricultural marketing society
Hypothetical facts (illustration only, not a real taxpayer): A co-operative society (not a consumers' co-operative society and not a co-operative bank) markets agricultural produce grown by its members, earning profits of ₹8,00,000. It also runs a small retail counter for the public, earning ₹70,000. It receives ₹40,000 interest on its investments (deposits) with another co-operative society and ₹1,20,000 rent from letting a warehouse for storage of commodities. Assume no deduction under Section 138 is available. Gross total income is ₹10,30,000.
Clause (a)(iii): marketing of members' produce
Whole of the profits deductible: ₹8,00,000.
Clause (c): other activity
The retail counter is not a clause (a) or (b) activity, so the deduction is capped at ₹50,000 (the society is not a consumers' co-operative society). Deduction: ₹50,000; the remaining ₹20,000 stays taxable.
Clause (d): interest from another co-operative society
Whole of the income deductible: ₹40,000.
Clause (e): warehouse letting
Whole of the income deductible: ₹1,20,000.
Clause (f)
Not relevant: gross total income of ₹10,30,000 exceeds ₹20,000.
Outcome
- Total Section 149 deduction = ₹8,00,000 + ₹50,000 + ₹40,000 + ₹1,20,000 = ₹10,10,000.
- Total income = ₹10,30,000 - ₹10,10,000 = ₹20,000, being the part of the retail-counter profit above the clause (c) cap.
Glossary
- Primary agricultural credit society
- The society type defined by the Banking Regulation Act cross-reference in the amended section.
- Consumers' co-operative society
- A society for the benefit of consumers under the statutory definition.
Frequently asked questions
Do all co-operative societies get a 100% deduction?
No. A 100% deduction applies to specified core activities such as banking/credit to members, cottage industry, agricultural marketing, and fishing. Income from other business activities is deductible only up to ₹1,00,000 (consumers' co-operative societies) or ₹50,000 (other societies).
Does interest or dividend income from another co-operative society qualify?
Yes - the whole of such income derived by a co-operative society from its investments with any other co-operative society, by way of interest or dividends, is deductible.
Are all co-operative banks eligible under Section 149?
No - the section does not apply to a co-operative bank unless it is a primary agricultural credit society or a primary co-operative agricultural and rural development bank.
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Talk to our tax team about co-operative society tax deductionsLast updated 10 October 2026