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2014 (4) TMI 1172 - ITAT COCHINDisallowance of deduction u/s 80P(2)(c) - whether the activities referred to in section 80P(2)(c) of the Act includes letting out of property and rental income received as income from house property? - Held that:- As in Kottayam Co-operative land Mortgage Bank Ltd vs CIT (1987 (10) TMI 16 - KERALA High Court) found that the term “activities” referred to in section 80P(2)(c) of the Act intended to cover receipts from sources other than actual conduct of business but attributable to an activity which results in profit or gain. The Kerala High Court found that rental income received on letting out of the property cannot partake the character of profit and gains attributable to an activity carried out by the assessee society, therefore, not entitled for exemption u/s 80P(2)(c) of the Act. Thus Letting out of the property and receipt of rental income is not an activity referred to in section 80P(2)(c) of the Act, therefore, not entitled for deduction u/s 80P(2)(c) of the Act. - Decided against assessee
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