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TMI Blog2023 (3) TMI 1046X X X X Extracts X X X X X X X X Extracts X X X X ..... so reproduced the submissions as well as the decisions relied upon by the assessee. It is pertinent to note that in the present assessee s case it is a Cooperative Society deriving interest from the member cooperative society and therefore, coming under the purview of Section 80P (2)(d) - assessee is entitled for deduction under Section 80P, the CIT(A) as well as the Assessing Officer has ignored ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come and hence not eligible for deduction u/s 80P(2)(a)(i) of the Act. 3. The assessee Shree Sarvodaya Sahakari Mandali Ltd. is an AOP/BOI (Cooperative Society) and has filed return of income for A.Y. 2018-19 on 05.10.2018 declaring NIL income. The case was selected for limited scrutiny on the issue of deduction from total income under Chapter VI-A. The Assessing Officer has taken date of fil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ny show-cause notice nor draft assessment order for proposed addition to the return of income. The Ld. A.R. further submitted that the Assessing Officer has not spelled out as to why the deduction claim under Section 80P has to be disallowed. The CIT(A) has reproduced the submissions of the assessee s and the case laws are simply observed that deduction claim under Section 80P is not allowable. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t as to why the disallowance under Section 80P was made in assessee s case. The CIT-A s order is also reproduced the submissions as well as the decisions relied upon by the assessee. It is pertinent to note that in the present assessee s case it is a Cooperative Society deriving interest from the member cooperative society and therefore, coming under the purview of Section 80P (2)(d) of the Act. T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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