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TMI Blog2022 (8) TMI 1291X X X X Extracts X X X X X X X X Extracts X X X X ..... not relevant. Thus overturn the impugned order on this score and allow the deduction. Deduction on dividend received through investment in shares - HELD THAT:- Section 80P(2)(d) provides that deduction shall be allowed in respect of any income by way of dividend derived by the Cooperative Society from its investment with any other Cooperative Society . Thus, it can be seen that the only requirement for claiming deduction u/s. 80P(2)(d) in respect of dividend is that it should be derived by the assessee cooperative society from its investments made with any other cooperative society. The assessee received dividend income in the instant case from another cooperative society, namely, Pune District Central Coop. Bank Ltd. Thus, the c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n an earlier case of Shri Laxmi Narayan Nagari Sahakari Pat Sanstha Maryadit Vs. ITO (ITA No.604/PN/2014) has allowed similar deduction. In the said case, the Tribunal discussed the contrary views expressed by the Hon ble Karnataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... core and allow the deduction. 6. The only other surviving issue is against denial of deduction of Rs.1,82,400/- on dividend received through investment in shares of Pune District Central Coop. Bank Ltd. The AO did not allow the deduction, which view came to be affirmed in the first appeal. 7. I have heard the rival submissions and gone through the relevant material on record. Section 80P(2)(d) provides that deduction shall be allowed in respect of any income by way of dividend derived by the Cooperative Society from its investment with any other Cooperative Society . Thus, it can be seen that the only requirement for claiming deduction u/s. 80P(2)(d) in respect of dividend is that it should be derived by the assessee cooperative ..... X X X X Extracts X X X X X X X X Extracts X X X X
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