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2022 (3) TMI 772 - ITAT PUNEDeduction u/s.80P(2)(a)(i) - Denial of deduction in respect of commission income received from Maharashtra State Electricity Distribution Company Limited (MSEDCL) and interest income earned on security deposit with MSEDCL - HELD THAT:-The activity of earning commission from collection of bills relating to MSEDCL has been held as eligible business activity and resultantly allowed granted deduction u/s.80P - DR fairly conceded the position but relied on the impugned orders on this score. In view of the fact that commission income on collection of bills from MSEDCL has been made eligible for deduction u/s.80P(2)(a) on the ground of the same being in the nature of business activity, we allow the assessee’s claim in respect of similar commission income Deduction u/s.80P(2) on the interest income on security deposit which was parked with MSEDCL for carrying on the business of collection of MSEDCL bills - In view of the fact that the activity of collection of bills has been held by the Tribunal in Banganga Nagri Sah. Patsanstha Ltd. [2016 (3) TMI 1434 - ITAT PUNE] as a business activity, whose income is eligible for deduction u/s.80P(2), the instant interest income of ₹ 20,000/- on security deposit with MSEDCL for carrying on the business of bill collection, which is a part and parcel of the overall activity of such business, cannot be accorded a different character.Therefore, order to grant deduction on interest on security deposit with MSEDCL - Assessee appeal allowed.
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