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2022 (8) TMI 1291

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..... ed against the order passed by the National Faceless Appeal Centre (NFAC), Delhi u/s.250 of the Income-tax Act, 1961 (hereinafter also called 'the Act') Act on 21-03-2022 in relation to the assessment year 2018- 19. 2. The first issue raised by the assessee is against the denial of deduction u/s.80P(2)(a)(i) of the Act amounting to Rs.33,74,652/- on interest income from bank. 3. Tersely stated, .....

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..... a Maryadit Vs. ITO (ITA No.604/PN/2014) has allowed similar deduction. In the said case, the Tribunal discussed the contrary views expressed by the Hon'ble Karnataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society .....

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..... is not relevant. The issue in that case was the eligibility of deduction u/s.80P(2)(d) of the Act on interest earned by the assessee co-operative society on investments made in co-operative banks. In that case, the assessee was engaged in the activity of marketing agricultural produce by its members; accepting deposits from its members and providing credit facility to its members; running stores, .....

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..... , which view came to be affirmed in the first appeal. 7. I have heard the rival submissions and gone through the relevant material on record. Section 80P(2)(d) provides that deduction shall be allowed "in respect of any income by way of ... dividend derived by the Cooperative Society from its investment with any other Cooperative Society". Thus, it can be seen that the only requirement for claimi .....

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