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TMI Blog2023 (4) TMI 894X X X X Extracts X X X X X X X X Extracts X X X X ..... s to augment the business activity of the assessee. In any case of the matter, as explained the interest income is also utilized for providing credit facility or repayment to members. Thus, interest income being inextricably linked to assessee s business activities as a credit society, would be eligible for deduction under Section 80P(2) - Decided in favour of assessee. - ITA No.346/Del/2023 - - - Dated:- 19-4-2023 - Shri Saktijit Dey, Judicial Member For the Appellant : Shri Yudhister Mehtani, CA For the Respondent : Shri D.K. Srivastav, Sr. DR ORDER This is an appeal by the assessee against order dated 15.12.2022 of National Faceless Appeal Centre (NFAC), Delhi pertaining to assessment year 2019-20. 2. The di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee is in the business of accepting deposits from members and providing credit facility to them at the time of their requirement, instead of transferring funds from its bank account, it transfers funds from the over draft facility availed by it by pledging its FDRs/deposits. He submitted, the investment in fixed deposits is only for purposes of availing over draft facility from the bank which is utilized for providing credit facility and repayment of deposits to its members. Further, he submitted, instead of keeping this surplus funds and not immediately required for deployment in the current account, the assessee had kept the funds in fixed deposits so as to facilitate immediate transfer of funds to members from the over draft account ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ds to members either as loan or as repayment. Thus, it can be seen that the investment in fixed deposits is to augment the business activity of the assessee. In any case of the matter, as explained before me by the learned counsel for the assessee, the interest income is also utilized for providing credit facility or repayment to members. Thus, in my view, the interest income being inextricably linked to assessee s business activities as a credit society, would be eligible for deduction under Section 80P(2) of the Act. The decisions relied upon by learned counsel clearly support this view. Accordingly, I direct the Assessing Officer to allow assessee s claim of deduction under Section 80P(2) of the Act on Rs.32,30.040. 8. In the result, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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