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TMI Blog1998 (6) TMI 2X X X X Extracts X X X X X X X X Extracts X X X X ..... or the Appellant. K.N. Shukla, Hemant Sharma, N.D.B. Raju and B.K. Prasad For the Respondent G. Sarangi and Ms. Janaki Ramachandran JUDGMENT M. SRINIVASAN J.---The respondent hereinafter referred to as the "assessee" is a co-operative society engaged in banking business. For the assessment years 1977-78, 1978-79 and 1979-80, the assessee claimed deduction under section 80P(2)(a)(i) of the Inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uently, the appeal was allowed and the matter was remitted to the Income-tax Officer to determine the deduction available to the assessee under section 80P(2)(a)(i). On a reference under section 256(2), the High Court of Karnataka agreed with the Tribunal and answered the question in favour of the assessee. The aggrieved Revenue has preferred this appeal. Section 80P(1) and (2)(a)(i) are in the f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome in question is attributable to the said activity, there is no doubt that the same is to be deducted from the gross total income. The Tribunal has found in this case that the interest income is attributable to the business of the assessee. That finding has not been challenged on factual basis by the Revenue. No materials have been placed before us to upset the factual conclusion of the Tribun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r section 81 (now section 80P) of the Income-tax Act. The decision was rendered on the facts of that case and it is not applicable in the present case in view of the finding of the Tribunal that the income in question is attributable to the business of the assessee. Learned counsel for the assessee has invited our attention to sections 24 and 56 of the Banking Regulation Act, 1949, as well as sec ..... X X X X Extracts X X X X X X X X Extracts X X X X
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