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2020 (3) TMI 681 - AT - Income TaxDisallowance u/s 80P(2)(a)(i) - HELD THAT:- The assessee has earned interest income on surplus funds deposited with nationalized bank and the cooperative Bank and the same is not attributable to business operation of the assessee co-operative society as interest earned on the fund invested with the commercial bank is not operational income from providing credit facilities to its members. We consider that earning of such interest income either from nationalized or cooperative bank will not change nature and character of the income. On perusal of the provision of section we observe such deduction is pertinent to the operational income earned by the co-operative society from the activities in which it is engaged and not the other income which accrues to the society in the form of interest from investment of surplus funds with the cooperative bank. No merit in the appeal of the assessee, therefore, the same is dismissed. However as decided in the various decision of SHREE RAM CO-OP. CREDIT SOCIETY LTD [2020 (3) TMI 619 - ITAT AHMEDABAD] we direct the assessing officer to allow pro rata expenses in respect of interest earned from deposit held with nationalized bank to the assessee for computing the deduction u/s. 80P after examining/verification and affording adequate opportunity to the assessee.
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