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2019 (7) TMI 1051 - HC - Income TaxSection 14A application in respect of the income not being taxable on account of deduction under Section 80P(2)(d) - no nexus between the interest /dividend income earned from the Cooperative Societies and the interest expenditure incurred by the assessee on borrowed funds on the ground that there is no proof of the investment of such interest bearing funds to earn the said income without appreciating the fact that the assessee has failed to substantiate the above in full measure with proper evidences? - HELD THAT:- As relying on SURAT DISTRICT CO. OP. MILK PRODUCER UNION LTD. [2014 (6) TMI 1027 - GUJARAT HIGH COURT] in view of decision decision of the Hon'ble Supreme Court in the case of Distributors (Baroda) P. Ltd vs. Union of India [1985 (7) TMI 1 - SUPREME COURT] we are in complete agreement with the view taken by the learned Tribunal allowing the deduction to the assessee under Section 80P(2)(d) of the Act on the amount of interest and dividend earned on the investment / deposits with the other cooperative societies. We see no reason to interfere with the impugned judgment and order passed by the learned Tribunal. Under the circumstances, in all these appeals with respect to grant of deduction under Section 80P(2)(d) of the Act is held against the revenue
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