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2023 (4) TMI 481 - ITAT HYDERABADDeduction u/s 80P(2)(a)(i) - interest derived by the assessee on the deposits in the Andhra Bank and the Indian Bank on the credit balance available therein - Scope of expressions, namely, "derived from" or "directly attributable to" - HELD THAT:- In the case on hand, 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] 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". It, therefore, goes without saying that the interest credited by the Andhra Bank and the Indian Bank 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) - AO will accordingly delete the disallowance. Decided in favour of assessee.
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