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TMI Blog2022 (5) TMI 1084X X X X Extracts X X X X X X X X Extracts X X X X ..... TMI 536 - SUPREME COURT] - Moreover similar issue was elaborately dealt by a larger bench of Honourable Supreme Court in the case of The Mavilayi Service Cooperative Bank Ltd. Ors. Vs. CIT, Calicut Ors. [ 2021 (1) TMI 488 - SUPREME COURT] and the issue was decided in favour of the assessee. - I.T.A. No. 1735/Mum/2021 - - - Dated:- 2-5-2022 - Shri Shamim Yahya (AM) For the Assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entatives. 3. Brief facts are that the assessee is The Indian Bank Employees Cooperative Credit Society Limited. On perusal of the profit and loss account and the computation of income, the Assessing Officer observed that the assessee has offered net income from business and profession at Rs. 40,31,437/- being interest receipts/dividend from Cooperative Bank and deduction under section 80P of R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5 of 2017 vide order dated 8.8.2017). Moreover similar issue was elaborately dealt by a larger bench of Honourable Supreme Court in the case of The Mavilayi Service Cooperative Bank Ltd. Ors. Vs. CIT, Calicut Ors. (Civil Appeal Nos. 7343-7350 of 2019 dated 12.1.2021) and the issue was decided in favour of the assessee. We may gainfully refer to the Hon'ble Apex Court observation in para 21 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ltd. and Ors. (supra) has construed section 80P widely and liberally, holding that if a society were to avail of several heads of deduction, and if it fell within any one head of deduction, it would be free from tax notwithstanding that the conditions of another head of deduction are not satisfied; (IV) This is for the reason that when the legislature wanted to restrict the deduction to a parti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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