TMI Blog2024 (5) TMI 393X X X X Extracts X X X X X X X X Extracts X X X X ..... ED case [ 2015 (2) TMI 995 - KARNATAKA 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, we direct the Assessing Officer to allow the exemption u/s. 80P(2)(a)(i) and section 80P(2)(d) of the Act. Thus, the grounds of appeal filed by the assessee stand allowed. - Shri Inturi Rama Rao, Accountant Member And Shri Vinay Bhamore, Judicial Member For the Assessee : None For the Revenue : Shri Manoj Tripathi ORDER PER INTURI RAMA RAO, AM: This is an appeal filed by the assessee directed against the order of Addl./JCIT(A)-2, Delhi dated 08.03.2024 for the assessment year 2015- 16. 2. Briefl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rence is called for. 7. Heard the ld. DR and perused the relevant material on record. The issue in the present appeal relates to the eligibility of the assessee for exemption u/s 80P(2)(a)(i) or u/s 80P(2)(d) of the Act in respect of interest income earned from Nationalised banks/cooperative banks. We find this issue is no more res integra by virtue of 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 allowing deduction u/s. 80P. 8. As regards, the issue as to the allowability of exemption under the provisions of section 80P(2)(a)(i) in respect of in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ligible 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 Samity Ltd., 147 taxmann.com 518 (Calcutta) and the Hon ble Madras High Court in the case of Chennai Central Co- operative Bank Ltd. vs. ITO, 148 taxmann.com 17 (Madras). The Coordinate Bench of Pune Benches in the case of M/s. Ratnatray Gramin Bigar Sheti Sah. Pat Sanstha Maryadit Vs. ITO (ITA Nos.559/560/PUN/2018, dated 11-12-2018) taken view in favour of the assessee following the judgment of Hon ble Karnataka High Court in the case of Tumkur Merchants Souharda Credit Cooperative Ltd. (supra). Following the decision of the Coordinate Bench of the Tribunal, we are of the con ..... X X X X Extracts X X X X X X X X Extracts X X X X
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