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2024 (2) TMI 333 - AT - Income TaxDeduction u/s 80P(2)(d) - interest received from Co-operative bank - HELD THAT:- As the issue is squarely covered in favour of the assessee by the decision of The Amroli Vibhag Vividh Karyakari Sahkari M. Ltd. [2024 (2) TMI 242 - ITAT SURAT] and there is no change in facts and law and the Revenue is unable to produce any material to controvert the aforesaid findings of the judgment as held Section 80P(2)(d) of the Act allows whole deduction of an income by way of interest or dividends derived by the co-operative society from its investment with any other co-operative society. This provision does not make any distinction in regard to source of the investment because this Section envisages deduction in respect of any income derived by the co-operative society from any investment with a co-operative society. It is immaterial whether any interest paid to the co- operative society exceeds the interest received from the bank on investments. The Revenue is not required to look to the nature of the investment whether it was from its surplus funds or otherwise. The Act does not speak of any adjustment as sought to be made out by learned counsel for the Revenue. The provision does not indicate any such adjustment in regard to interest derived from the co-operative society from its investment in any other cooperative society. Therefore, we direct the Assessing Officer to allow the deduction under section 80P(2) (d) of the Act in respect of interest received from Co-operative bank. Appeal of assessee allowed.
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