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2012 (11) TMI 591

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..... also a part of the activity of banking. Therefore, the interest earned on such deposits is directly attributable to the business of banking followed by decision of court in case of [Mehsana District Co-operative Bank Ltd. Versus Income-Tax Officer 2001 (8) TMI 15 - SUPREME COURT] decided in favour of the assessee and against the revenue and the present appeals are also dismissed. - ITA No. 45 & .....

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..... ess/activities? 2. Whether the ITAT was correct in law in holding that the issue regarding allowability of deduction s 80P (2) (a) (i) of the Income Tax Act in respect of such income had been settled by the Hon'ble Supreme Court in the case of Nawanshaher Central Coop. Bank, whereas that judgment related to income from investment of statutory reserves only? 3. These questions have already bee .....

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..... d to accept this argument. In the case before the Apex Court, the Bank had lost throughout before the revenue authorities as well as the High Court. None of the authorities had considered the question whether the income from interest of Non-SLR reserves was attributable to normal banking activities. It was in these circumstances that the Supreme Court directed that the matter be remanded to the Co .....

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..... second phrase used is any one or more of such activities. Any banking business providing credit facilities to its members and investing the sums deposited by the members of the society is part of banking business. We are, therefore, of the considered view that the investment of the funds by the banks including the non-reserves were part of the banking activities since no bank would like its rese .....

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