2022 (3) TMI 772

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..... ese two appeals by the assessee relating to the assessment years 2017-18 and 2018-19 arise out of the orders dated 26-10- 2021 passed by the CIT(Appeals) National Faceless Appeal Centre (NFAC), Delhi u/s 250 of the Income-tax Act, 1961 (hereinafter also called `the Act'). Since a common issue is raised in both the appeals, I am, therefore, proceeding to dispose them off by this consolidated order .....

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..... s. 60,363/- from MSEDCL; and interest of Rs. 20,000/- on security deposit with MSEDCL - on the ground that these items of income were not from the business of providing credit facilities to its members. To sum up, the assessee's claim for deduction u/s.80P(2)(a)(i) was denied on a total income of Rs. 1,95,015/-. The ld. CIT(A) accepted the assessee's contention anent to the interest income of Rs. .....

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..... ssue came up for consideration before the Pune Tribunal in Banganga Nagri Sah. Patsanstha Ltd. (ITA No.873/PUN/2014) and the Tribunal, vide its order dated 31- 03-2016, allowed the deduction on commission of collection of MSEDCL bills by holding that it was from the business activity carried on by the assessee. The Tribunal, for allowing such deduction in Banganga Nagri Sah. Patsanstha Ltd. (supra .....

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..... inst the denial of deduction u/s.80P(2) on the interest income of Rs. 20,000/- on security deposit which was parked with MSEDCL for carrying on the business of collection of MSEDCL bills. In view of the fact that the activity of collection of bills has been held by the Tribunal in Banganga Nagri Sah. Patsanstha Ltd. (supra) as a business activity, whose income is eligible for deduction u/s.80P(2), .....

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..... lection is identical to the one considered above for the immediately preceding assessment year 2017-18. Following the view taken for such earlier year, I order to allow deduction u/s.80P(2)(a) on the commission income earned from MSEDCL bill collection 9. In the result, both the appeals are allowed. Order pronounced in the Open Court on 14th March, 2022.
Case laws, Decisions, Judgements, Ord .....

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