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2021 (3) TMI 159 - AT - Income TaxDeduction u/s 80P - disallowing its interest income as not entitled for 80P deduction since derived from deposits made in scheduled banks - HELD THAT:- In decision in Vavveru Co-operative Rural Bank Ltd., Vs. CIT [2017 (4) TMI 663 - ANDHRA PRADESH HIGH COURT] holds the very nature of income as eligible for Section 80P deduction held that original source of the investments made by the petitioners in nationalised Banks is admittedly the income that the petitioners derived from the activities listed in sub Clauses (i) to (vii) of Clause (a). The character of such income may not be lost, especially when the statute uses the expression "attributable to" and not anyone of the two expressions, namely, "derived from" or "directly attributable to". Therefore, we are of the considered view that the petitioners are entitled to succeed. Hence direct the Assessing Officer to delete the impugned disallowance thereby treating that the assessee as eligible for Section 80P deduction. - Decided in favour of assessee.
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