TMI Blog2024 (4) TMI 647X X X X Extracts X X X X X X X X Extracts X X X X ..... nd Vaveru Co-operative Rural Bank Ltd [ 2017 (4) TMI 663 - ANDHRA PRADESH HIGH COURT] took a view that such interest income is attributable to the activities of the society and, therefore, eligible for exemption u/s 80P(2)(a)(i) of the Act. Similar view has been taken by the Hon ble Calcutta High Court in the case of PCIT vs. Gunja Samabay Krishi Unnayan Samit [ 2023 (1) TMI 783 - CALCUTTA HIGH COURT] and Chennai Central Cooperative Bank Ltd. [ 2023 (1) TMI 1088 - MADRAS HIGH COURT] The interest income earned on fixed deposits with cooperative bank/scheduled bank partakes character of the business income, which is eligible for deduction u/s 80P(2)(a)(i) of the Act. Therefore, direct the Assessing Officer to allow the exemption u/s. 80P(2)(a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Assessing Officer. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. It is submitted before me that the issue is decided in favour of the assessee by placing reliance on the several decisions of the Tribunal as well as the decision of the Co-ordinate Bench of this Tribunal in the case of Sai Prerana Gramin Bigarsheti Sahakari Pat Sanstha Maryadit Vs. ITO and others in ITA No.1431/PUN/2018 and others dt. 03.07.2019, copy placed at page 7 to 14 of the paper book. 6. On the other hand, ld. Sr. DR placing reliance on the orders of the lower authorities submits that no interference is called for. 7. I heard the rival submissions and perused the material on record. The issue in the present appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on ble Punjab Haryana High Court in the case of CIT Vs. Punjab State Cooperative Agricultural Development Bank Ltd. 389 ITR 68 and the Hon ble Kolkata High Court in the case of CIT Vs. Southern Eastern Employees Cooperative Credit Society Ltd. 390 ITR 524 took a view that the income arising on the surplus invested in short term deposits and securities cannot be attributed to the activities of the society and, therefore, not eligible for exemption u/s. 80P(2)(a)(i) of the Act. However, the Hon ble Karnataka High Court in the case of Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 taxmann.com 309 (Kar.) and the Hon ble Telangana and Hon ble Andhra Pradesh High Court in the case of Vaveru Co-operative Rural Bank Ltd. v CIT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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