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2023 (6) TMI 1206 - AT - Income TaxScope of limited scrutiny assessment - Addition made on account of interest income not returned to tax by the assessee - HELD THAT:- As the addition made on account of interest earned from bank by the assessee is set aside as the same is beyond the scope of limited scrutiny assessment. The said action could not have been made in the present limited scrutiny assessment by the AO. The addition is therefore is not sustainable in law, and directed to be deleted, and the ground of the assessee is allowed. Denial of deduction u/s 80P(2)(a)(i) - income earned from activities of providing bills collection facilities to its members - HELD THAT:- The said clause of section 80P allows deduction only of income earned by cooperative societies from the business of providing banking or credit facilities. Assessee has been unable to demonstrate as to how this income qualifies for deduction under clause (a) of section 80 P(2) of the Act. Therefore agree with the ld.CIT(A) that the assessee is not entitled to deduction of income earned from the activities of providing bills collection services to its members under section 80P(2)(a)(i) of the Act and, the ld.CIT(A) hold has rightly disallowed the same. Set off expenses incurred for earning of incomes to which the assessee was denied deduction under section 80P(2) at the rate of 5% thereof - contention of assessee was that the estimation ought to have been done on reasonable basis and for such purpose, he requested the matter to be restored back - HELD THAT:-As find merit in the contentions of assessee that there has to be a reasonable basis for arriving at any estimation, and in the absence of any such basis being provided by the ld.CIT(A),restore this issue back to the ld.CIT(A) to estimate the expenses to be allowed against the income from other sources liable to tax on a reasonable basis. Ground of appeal is allowed for statistical purposes.
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