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2023 (6) TMI 1032 - AT - Income TaxDeduction u/s 80P(2)(a)(i) - interest derived by the assessee on the deposits in the State Bank of Hyderabad on the credit balance available therein - HELD THAT:- Undisputedly, the interest arose on the credit balances with reference to the regular course of business of the assessee. As decided in Vavveru Co-operative Rural Bank Ltd. [2017 (4) TMI 663 - ANDHRA PRADESH HIGH COURT] held that, if the original source of the investments made by the petitioners in nationalized banks is admittedly the income that the petitioners derived from the activities listed in sub-clauses (i) to (vii) of clause (a), then the character of such income may not be lost, especially when the statute uses the expression "attributable to" and not any one of the two expressions, namely, "derived from" or "directly attributable to". Interest credited by the State Bank of Hyderabad to the account of the assessee on the credit balances does not lose its character as the income derived from the activities of the assessee covered by 80P(2)(a)(i) - Thus disallowed interest in this matter, as a matter of fact is eligible for deduction under section 80P(2)(a)(i) - Decided in favour of assessee.
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