TMI Blog2022 (7) TMI 1001X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee. Accordingly, this ground of the assessee s appeal is dismissed. Disallowing the deduction of interest income - investment made out of the surplus funds with Jharkhand State Co-operative Bank - Whether interest income earned from that investment is eligible for deduction or not - HELD THAT:- A perusal of sub-Section (d) would indicate that in respect of any income by way of interest or dividend derives by the co-operative society from its investment with any other co-operative society, the whole of such income shall be eligible for deduction. The whole of income earned from co-operative society by an assessee by way of the interest or dividend shall be eligible for deduction u/s 80P(2)(d) of the Act. The Jharkhand State Coopera ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . During the year, the assessee society received a contract from M/s. Tata Motors Ltd. of Rs.64,43,654/-, for maintaining the horticulture of the compound. The assessee has outsourced this job and shown profit at 2.94% in the accounts. The Assessing Officer was not satisfied with the calculation of this profit at Rs.1,89,518/-. He was of the view that the assessee should have shown profit at least @ 8% of the total receipt. The Assessing Officer confronted the assessee with regard to the above and ultimately recorded a finding in paragraph nos. 3.5. 3.6. of the assessment order that, the assessee failed to give any evidence for low profit. The Assessing Officer estimated the profit @ 8 % which comes to Rs.5.15.492/-. After debiting the pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eligible for deduction which is earned on statutory deposits. In other words, the ld. First Appellate Authority was of the view that if some Fixed Deposits were made by the assessee for statutory compliance to run the society then, the interest income, though incidental one, be allowed as a deduction. Rest the ld. CIT(A) did not allow. 7. The simple issue before the Tribunal is that investment made out of the surplus funds with Jharkhand State Co-operative Bank. Whether interest income earned from that investment is eligible for deduction or not. This claim has been made by the assessee u/s 80P(2)(d) of the Act. We deem it appropriate to take note of these provisions which read as under:- 80P. (1) Where, in the case of an assessee b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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