9911796707
TMI Blog2022 (1) TMI 642X X X X Extracts X X X X X X X X Extracts X X X X ..... le for section 80P(aa) deduction qua, the interest income derived from deposits made in the nationalized banks is no more res integra as the Tribunal coordinate bench decision in [ 2021 (9) TMI 1327 - ITAT HYDERABAD] takes note of the hon'ble jurisdictional High Court decision in Vavveru Coop. Rural Bank [ 2017 (4) TMI 663 - ANDHRA PRADESH HIGH COURT ] hold that both the Assessing Officers therein had not committed any error in not disallowing the assessees' section 80P(2)(d) deduction claims in issue qua the respective interest income derived form fixed deposit in nationalised banks. The PCITs' revision direction under challenge herein forming subject matter of these two appeals stand reversed on the very analogy therefore. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. We next advert the sole substantive issue between the parties, qua correctness of the Pr. CIT's identical revision direction treating the corresponding regular assessments, dated 28.6.2017, 29.6.2017 and 27.6.2017; respectively as erroneous ones causing prejudice to the interest of the Revenue on the ground that the Assessing Officer (s) had accepted these taxpayer identical section 80P(aa) deduction claims pertaining to the interest income derived from nationalized banks. Learned Pr. CIT holds that the hon'ble apex court's decision in Totgars Co-operative Society Ltd. vs. Income Tax Officer (322 ITR 283) (S.C) as well as CIT vs. Nawanshahar Central Co-op Bank Ltd. (289 ITR 6) (S.C) have already held that such deduction i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itution than deposits made in nationalized banks. Learned PCIT therefore hold both the foregoing assessments as an instance inviting application of ITA Nos. 284 286/Hyd/2021 section 263 revision jurisdiction. This leaves the assessees' aggrieved. 4. We have given our thoughtful consideration to rival pleadings qua correctness of the learned PCITs foregoing revision direction and find no reason to uphold the same. This is primarily for the reason that hon'ble jurisdictional high court decision in Vavveru Co-operative Rural Bank Ltd. Vs. CCIT 396 ITR 371 (A.P) holds that a co-operative society's income derived from deposits in nationalized banks/SBI is also eligible for 80P deduction. Their lordships have duly taken into co ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
