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2022 (3) TMI 772

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..... ade eligible for deduction u/s.80P(2)(a) on the ground of the same being in the nature of business activity, we allow the assessee s claim in respect of similar commission income Deduction u/s.80P(2) on the interest income 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. [ 2016 (3) TMI 1434 - ITAT PUNE] as a business activity, whose income is eligible for deduction u/s.80P(2), the instant interest income of ₹ 20,000/- on security deposit with MSEDCL for carrying on the business of bill collection, which is a part and parcel of the overall ac .....

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..... P of the Act on - interest income of ₹ 1,14,652/- from Nationalized bank; Commission income of ₹ 60,363/- from MSEDCL; and interest of ₹ 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 ₹ 1,95,015/-. The ld. CIT(A) accepted the assessee s contention anent to the interest income of ₹ 1,14,652/- by relying on certain Tribunal orders. He, however, disapproved the assessee s claim of deduction u/s.80P(2)(a) on commission income of ₹ 60,363/- earned from MSEDCL and interest at ₹ 20,000/- from MSEDCL on s .....

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..... collection of bills from MSEDCL has been made eligible for deduction u/s.80P(2)(a) on the ground of the same being in the nature of business activity, I allow the assessee s claim in respect of similar commission income of ₹ 60,363/-. 6. The other point raised in this appeal is against the denial of deduction u/s.80P(2) on the interest income of ₹ 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), the instant interest income of ₹ 20,000/- on .....

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