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2023 (7) TMI 1042 - AT - Income TaxRevision u/s 263 - deduction of interest u/s 80P(2)(d) - HELD THAT:- The assessee before us, is a cooperative society registered under the provisions of Gujarat Co-operative Societies Act-1961.The case was selected for scrutiny for examination of deduction of Chapter-VIA. We find that during the assessment order the assessing officer issued specific show cause notice for examination of deduction under Chapter VIA. The assessee filed its reply and explained the admissibility of deduction under section 80P, specifically about the deduction of Rs. 2.01 Crore claimed under section 80P(2)(d). No doubt, there is no reference about the examination of such issue, however, admittedly the issue was examined by the assessing officer. PCIT revised the assessment order on the issue of deduction under section 80P(2)(d). On carful considerations of grounds of appeal and the facts of the case, we find that on similar grounds of appeal on similar set of facts, this combination has this Tribunal allowed similar relief to that assessee, thus in our view, the grounds of appeal raised by the assessee are square covered in favour of assessee and against the revenue. Thus, we hold that the order of ld PCIT passed under section 263 is not justified - Grounds of appeal allowed in favour of the assessee and against the revenue.
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