TMI Blog2023 (7) TMI 860X X X X Extracts X X X X X X X X Extracts X X X X ..... td. [ 2017 (1) TMI 1601 - ITAT AHMEDABAD] it will be appropriate to remand back this issue thereby directing the Assessing Officer to verify the assessee s claim of pro-rata expenses by examining the record which has to be shown for verification by the assessee - Appeal of the assessee is partly allowed for statistical purpose. - I.T.A. No. 120/Ahd/2023 - - - Dated:- 19-7-2023 - Ms. Suchitra Kamble, Judicial Member For the Appellant : Shri Samir Parikh, A.R. For the Respondent : Shri B. P. Makwana, Sr. D.R. ORDER The appeal filed by the assessee is against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short Ld. CIT(A) ), National Faceless Appeal Centre (in short NFAC ), Delhi on 16.02.2023 f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fter claiming deduction under Section 80P(2)(a)(i). The case was selected for scrutiny and notice was issued on 06.01.2017 after taking cognizance of the reply of the assessee. The Assessing Officer held that the interest income of Rs. 2,20,808/- from Nationalized Bank was not justifiable for claiming deduction under Section 80P(2)(a)(i) of the Act. 4. Being aggrieved by the assessment order the assessee filed appeal before the CIT(A). The CIT(A) partly allowed the appeal of the assessee. 5. The Ld. A.R. submitted that the CIT(A) has not taken the cognizance of the ground related to pro-rata expenses for earning interest income. The Ld. A.R. further submitted that the assessee society has made investment out of deposits collected from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 60 taxmann.com 215 (Karnataka). The Ld. A.R. also relied upon the decision of Hon ble Apex Court in case of Mantola Co-operative Thrift Credit Society Ltd. vs. CIT 70 taxmann.com 296 (SC) wherein it is held that where a cooperative society engaged in providing credit facilities to its members, deposited surplus funds in fixed deposits and earned interest thereon, said interest would be eligible for deduction under Section 80P(2)(a)(i) of the Act. The Ld. A.R. as regards to Ground 4 in respect of without prejudice submitted that pro-rata expenses for earning interest income has to be allowed. The Ld. A.R. submitted that total expenditure incurred for the year was at Rs. 16,09,394/-, total income for the year was at Rs. 17,60,194/- and inte ..... X X X X Extracts X X X X X X X X Extracts X X X X
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