2021 (12) TMI 405 - ITAT AHMEDABAD - Income Tax

Head Note / Extract:
Deduction u/s 80P - profits and gains attributable to non-members arising as a result of advancement of loans - assessee's (cooperative societies) engaged in the providing credit facilities to the non-members along with its members - HELD THAT:- As decided in case THE MAVILAYI SERVICE COOPERATIVE BANK LTD. & ORS. [2021 (1) TMI 488 - SUPREME COURT]absolute denial of deduction under Section 80P(2)(a)(i) of the Act to the assessee's (cooperative societies) engaged in the providing credit facilities to the non-members along with its members is not warranted under the Act and only that part of profit and gains that is attributable and/or pertains to the non-members shall not be allowed as deduction under Section 80P(2)(a)(i). Thus, the profits and gains attributable to non-members arising as a result of advancement of loans was held to be not an allowable deduction under Section 80P(2)(a)(i) of the Act. - Appeal of the assessee is dismissed.