TMI Blog2023 (3) TMI 819X X X X Extracts X X X X X X X X Extracts X X X X ..... Bank Limited [ 2021 (1) TMI 488 - SUPREME COURT ] has taken a view that Section 80P being a benevolent provision enacted by the Parliament to encourage and promote the credit of the co-operative sector in general must be read liberally and reasonably. Various decisions especially that of Apex Court in Totgar s Co-operative Sales Society Limited [ 2010 (2) TMI 3 - SUPREME COURT ] and SBI [ 2016 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee against order dated 20.09.2022 passed by the CIT(A), National Faceless Appeal Centre (NFAC), Delhi for the Assessment Year 2018-19. 2. The assessee has raised the following ground of appeal :- 1. The Ld. CIT(Appeal) National Faceless Appeal Centre Delhi has erred in law and on fact of the case and not justified in confirming disallowance made by CIT(A) of Rs.17,30,372/-, the interest re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r observed that the assessee has shown fixed deposit interest income and savings bank interest income of Rs.11,34,554 but Rs.17,30,372/- was the actual interest,. The assessee claimed deduction under Section 80P(2)(d) for Rs.17,30,372/- which was interest received from Mehsana Urban Co-operative Bank. The Assessing Officer held that the Urban Co-operative Banks are out of ambit of Co-operative Soc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s well as the decision of Hon ble Gujarat High Court in the case of SBI vs. CIT, 389 ITR 578 and Totgar s Co-operative Sales Society Limited vs. ITO, 188 Taxman 282 decided by the Hon ble Apex Court. 7. Heard both the parties and perused all the relevant material available on record. The decision of the Hon ble Apex Court in the case of Mavilayi Service Co-operative Bank Limited has taken a vie ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
