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TMI Blog2022 (2) TMI 118X X X X Extracts X X X X X X X X Extracts X X X X ..... in the first appeal by the ld. CIT(A) allowing proportionate deduction - HELD THAT:- CIT(A) has accepted the assessee s contention, in principle, about the eligibility of deduction u/s.80P(2) of the Act on interest income. He, however, restricted the benefit proportionately by considering the total receipts of the assessee vis- -vis the amount of interest income. Once the ld. CIT(A) accepted the c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... profit of ₹ 11,50,144/- which was claimed as deduction u/s.80P(2)(a) of the Income-tax Act, 1961 (hereinafter also called 'the Act'). The AO denied the benefit of deduction u/s.80P on the ground that the amount of interest income did not qualify, which view came to be countenanced partly in the first appeal by the ld. CIT(A) allowing proportionate deduction. 3. I have heard the rival submis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d. Vs. CIT (2014) 110 DTR 89 (Delhi) not allowing deduction u/s.80P on interest income earned from banks. Both the Hon'ble High Courts took into consideration the ratio laid down in the case of Totgar's Cooperative Sale Society Ltd. (supra). No direct judgment from the Hon'ble jurisdictional High Court on the point having been pointed out, the Tribunal in Shri Laxmi Narayan Nagari Sahakari Pat San ..... X X X X Extracts X X X X X X X X Extracts X X X X
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