TMI Blog1998 (6) TMI 2X X X X Extracts X X X X X X X X Extracts X X X X ..... deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961, on the income by way of interest on Government securities and dividends on shares of the Industrial Financial Corporation - claim of special deduction is accepted - CIVIL APPEAL NOS. 1300-1302 OF 1993 - - - Dated:- 24-7-1998 - MRS. SUJATA V. MANOHAR AND M. SRINIVASAN, JJ. For the Appellant. K.N. Shukla, Hemant Sharma, N.D.B. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld that the investment was out of the reserve fund. Consequently, he confirmed the order of the Income-tax Officer. On further appeal, the Tribunal accepted the contention of the assessee that interest income was attributable to the assessee's business income. The Tribunal followed its earlier order in I. T. A. Nos. 665 to 668 of 1981 dated July 30, 1982. Consequently, the appeal was allowe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... --- (a) in the case of a co-operative society engaged in--- (i) carrying on the business of banking or providing credit facilities to its members, or---... the whole of the amount of profits and gains of business attributable to any one or more of such activities. There is no dispute that the assessee is a co-operative society carrying on the business of banking. If the income in ques ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ofits and Government securities coming out of the reserve fund which could not be easily encashed and which could be utilised only when contingencies arose, could not be considered to be circulating capital or stock-in-trade. It was therefore held that interest on Government securities placed with the State Bank of India and the Reserve Bank of India could not qualify for exemption under section 8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thin the scope of section 80P(2)(a)(i). He has also referred to the rulings in Bihar State Co-operative Bank Ltd. v. CIT [1960] 39 ITR 114 (SC) ; Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84, in support of his contentions that the expression attributable to is of very wide import. It is unnecessary in this case to consider the same in detail. On the fact situation of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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