Section 80P of the Income Tax Act, 1961— Deduction — Primary co-operative societies procured milk from members and supplied to assessee and assessee in turn supplied to Mother Dairy under control of Gujarat Milk Marketng Federation and these primary Co-operative societies cannot operate without assessee being a district level society and assessee's activities were interlinked with activities of primary Co-operative Societies, the assessee was not a federal co-operative society to whom these primary Co-operative Societies supplied milk and even the primary Co-operative Societies would not be eligible to enjoy the income benefit of the deduction provided under section 80P(2)(b), thus in such a situation the provisions of section 80P(2)(b) should be read liberally and assessee had been claiming the deduction under section 80P(2)(b) consistently for several assessment years and there was no disallowance, therefore, the claim of the assessee should be allowed on the basis of the principles of consistency—Surendranagar District Co-operative Milk Producers Union Ltd. vs. Deputy Commissioner of income tax [2019] 75 ITR (trib) 339 (Rakjot)