TMI Blog2020 (5) TMI 212X X X X Extracts X X X X X X X X Extracts X X X X ..... it facilities to its Members and supply of fertilizers and other materials used in the agricultural activity to the members, the same is eligible for deduction u/s 80P - interest earned by the assessee from the deposits with another cooperative banks is also eligible for deduction u/s 80P but the interest earned from the saving bank account kept with schedule bank or non-cooperative bank is again a matter of dispute, so far as the eligibility of deduction u/s 80P of the Act is concerned. In the absence of these segmentwise details and income from different activities bifurcating into the category of core activity and ancillary activity to the core activity as well as non-core activity, it is not possible to consider the claim of deductio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion Scheme (for short PDS ) of the Rajasthan Govt. like Sugar, Kerosene, Wheat etc. The assessee filed its return of income on 15-08-2016 declaring Nil income after claiming deduction of ₹ 27,45,889/- u/s 80P of the I.T. Act, 1961. The AO has denied the claim of deduction u/s 80P of the Act on the ground that the assessee has not furnished the requisite details regarding claim of deduction u/s 80P of the Act. The assessee challenged the action of the AO before the ld. CIT(A) and contended that the assessee is eligible for deduction u/s 80P of the Act. The ld. CIT(A) has sustained the disallowance of deduction u/s 80P of the Act made by the AO on the ground that the assessee has not furnished any details with regard to its deduction ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... laimed deduction u/s 80P of the Act in respect of its entire income. During the course of assessment proceeding, the AO has disallowed the claim of the assessee in para 4 (a) as under:- 4. On scrutiny of the case, the following issue has been noticed:- (a) Disallowance on account of large deduction claimed under Chapter VIA During the course of assessment proceeding, on perusal of return of income it is noticed that assessee AOP has claimed large deduction u/s 80P of Chapter VIA amounting to ₹ 27,45,889/- but the assessee has not furnished any details with regard to this deduction. In view of above facts, it is clear that the assessee has failed to furnish the evidence of deduction claimed u/s 80P. It is, therefore, disa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee gives only the details of receipts/sales and expenditure incurred by the assessee during the year but it does not give details of segmentwise income for the purpose of verifying the claim of assessee's deduction u/s 80P of the Act. We find that some of the income during the year under consideration has been earned by the assessee from the activity of selling the commodities like Sugar, Kerosene, Wheat etc. under the Public Distribution Scheme of Rajasthan Govt. Therefore, these activities are not the core activity of the assessee society and the income from these activities would not be eligible for deduction u/s 80P of the Act. So far as the core activity of the assessee society which includes credit facilities to its Members ..... X X X X Extracts X X X X X X X X Extracts X X X X
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