Sale of products of member-employee by society isn't collective disposal of labour; no sec. 80P reli

IT : Where assessee, a co-operative society, was engaged in tapping of toddy from coconut trees and sale of toddy and all its member-employees were toddy tapping workers, since main objective of assessee was to run retail toddy shops and it had generated income only through sale of toddy, it could not be considered a co-operative society engaged in collective disposal of labour of its members as contemplated under section 80P(2)(a)(vi)