9911796707
TMI Blog2019 (1) TMI 851X X X X Extracts X X X X X X X X Extracts X X X X ..... ast the Tribunal in number of decisions has taken a consistent view on this issue by following above judgment of the Hon’ble jurisdictional High Court. In this view of the matter, we do not incline to disturb the orders of the Revenue on this issue, which we uphold. However, any expenditure incurred by the assessee for earning such income could be allowed to it. AO has to determine the net interest income earned by the assessee on such investment with bank, and only thereafter that income has to be excluded from the admissibility of deduction under section 80P(2) of the Act. Earning of interest income u/s 244A since this income is not attributable to the activities of the assessee-society, the same is not an eligible income for exemption. A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... activities of the assessee-society, the ld.AO show caused the assessee as to why the interest income should not be added back to the total income of the assessee. Assessee, inter alia, submitted that parking surplus money not immediately required for the day-to-day activities of the assessee is an integral part of its business activity, and therefore, eligible for exemption under section 80P(2) of the Act, and therefore, interest earned on such deposits was attributable to the business of the society. This submission of the assessee was not found acceptable to the AO by holding that the interest income earned by the assessee was not from its main activity of providing credit facilities to its members, rather such income was generated out fu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... igh Court. In this view of the matter, we do not incline to disturb the orders of the Revenue on this issue, which we uphold. However, any expenditure incurred by the assessee for earning such income could be allowed to it. In other words, the ld.AO has to determine the net interest income earned by the assessee on such investment with bank, and only thereafter that income has to be excluded from the admissibility of deduction under section 80P(2) of the Act. 5. So far as earning of interest income of ₹ 12,995/- under section 244A of the Act is concerned, since this income is not attributable to the activities of the assessee-society, the same is not an eligible income for exemption. The ld.AO has rightly made this addition. As regar ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
