TMI Blog2011 (4) TMI 1313X X X X Extracts X X X X X X X X Extracts X X X X ..... gainst the order of Income Tax Appellate Tribunal Panaji Bench (for short Appellate Tribunal) dated 26.03.2007 in ITA No. 36/PANJ/2007 confirming the order passed by the Commissioner of Income Tax (Appeals) dated 29.12.2006 and the order of assessment dated 09.03.2006 passed by the Assessing Officer. 2. The appellant is a Co- Operative Society Engaged in banking business. For the assessment yea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 80P(2)(a)(i) is not available for investments made in private limited companies or public limited companies? 4. It is necessary at this juncture to notice Section 80P(2)(a)(i) of the Income Tax Act and the same reads as under : SECTION 80P. DEDUCTION IN RESPECT OF INCOME OF CO- OPERATIVE SOCIETIES (1) (2) The sums referred to in sub- section (1) shall be the following namely ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earns interest falls under the definition of Banking . In the instant case, the assesse had the excess money with them which was not taken by its shareholders. Instead of keeping money idle with the assesse, they have deposited the same in a private limited company so that it can earn interest. In the instant case, the appellant assessee deposited the same in a private limited company namely M/s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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