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TMI Blog2022 (11) TMI 823X X X X Extracts X X X X X X X X Extracts X X X X ..... OUNTANT MEMBER: The captioned appeal has been filed at the instance of the Assessee against the order of the Learned Commissioner of Income Tax (Appeals), Gandhinagar, dated 11/08/2020 arising in the matter of assessment order passed under s. 143(3) of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Year 2017-18. 2. The only issue raised by the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of financing to the members. Thus, the AO disallowed the same and added to the total income of the assessee. 4. Aggrieved assessee preferred an appeal to the learned CIT (A), who confirmed the order of the AO. 5. Being aggrieved by the order of the learned CIT (A), the assessee is in appeal before me. 6. The learned AR before me fairly conceded that the assessee is not eligible for deduction wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity. In other words, the income from the activity of financing from the members is only eligible for deduction under section 80P(2)(a)(i) of the Act. If there is any income arising to the co-operative society from the non-members that will not be subject to deduction under section 80P(2)(a)(i) of the Act. In holding so, I draw support and guidance from the judgment of the Hon'ble Gujarat High Cour ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... view of the above, there remains no ambiguity that income received by the assessee for Rs. 4,52,905/- on the money deposited with the Bank of Baroda is not eligible for deduction under section 80P(2)(a)(i) of the Act. Before parting, the question arises whether gross amount of interest should be reduced from the claim made by the assessee for the deduction under section 80P(2)(a)(i) of the Act. I ..... X X X X Extracts X X X X X X X X Extracts X X X X
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