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TMI Blog2004 (4) TMI 19X X X X Extracts X X X X X X X X Extracts X X X X ..... the provisions of sub-section (2) of section 80J, the assessee being a cooperative society could carry forward and set off the deduction under section 80J against the income up to the assessment year 1984-85 only. The Commissioner also took the view that the deduction u/s 80P(2)(a)(i) and u/s 80P(2)(a)(iii) was not in order as the assessee was not one engaged in the business of banking or providin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome for the assessment years 1987-88 and 1988-89, the Assessing Officer allowed the assessee's claim for setting off the relief under section 80J, brought forward from the assessment years 1979-80 to 1984-85. For the assessment year 1987-88, the assessment order was passed under section 143(3) of the Income-tax Act, 1961 on February 28, 1990, and for the assessment year 1988-89 on October 24, 1990 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessments for both the years required to be revised, he issued a notice under section 263 of the Income-tax Act to the assessee. By a common order, the Commissioner directed the Assessing Officer to revise and modify the assessments by withdrawing the deduction allowed under section 80J so also to revise and modify the assessments by disallowing the deductions under section 80P(2)(a). Being agg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l assessment year. In the case of the assessee, the initial assessment year was 1978-79. The assessee being a co-operative society, the provisions of the sub-section (2) will have effect as if for the words "four assessment years", the words "six assessment years" had been substituted. If the six year period is reckoned from the assessment year 1978-79, it would expire with the assessment year 198 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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