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TMI Blog2023 (6) TMI 32X X X X Extracts X X X X X X X X Extracts X X X X ..... h Courts on the issue of eligibility of this kind of income for exemption u/s. 80P(2)(a)(i). The Coordinate Bench of Pune Benches in the case of M/s. Ratnatray Gramin Bigar Sheti Sah. Pat Sanstha Maryadit [ 2018 (12) TMI 1926 - ITAT PUNE] taken view in favour of the assessee following the judgment of Tumkur Merchants Souharda Credit Cooperative Ltd [ 2015 (2) TMI 995 - KARNATAKA HIGH COURT] Respec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eturn of Income for the assessment year 2017-18 was filed on 31.03.2018 disclosing total income of Rs.7,41,090/- after claiming deduction u/s 80P(2)(a)(i) of the Income Tax Act, 1961 ('the Act') of Rs.41,84,244/-. Against the said return of income, the assessment was completed by the Income Tax Officer, Ward-1, Satara ('the Assessing Officer') vide order dated 12.12.2019 passed u/s 143(3) of the A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case is as to the allowability of exemption under the provisions of section 80P(2)(a)(i) in respect of interest income earned by a cooperative society from the scheduled banks. There is a cleavage of judicial opinion among several High Courts on the issue of eligibility of this kind of income for exemption u/s. 80P(2)(a)(i) of the Act. The Hon'ble Punjab & Haryana High Court in the case of CIT vs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ver, the Hon'ble Karnataka High Court in the case of Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 taxmann 309 (Kar.) and the Hon'ble Telangana and Hon'ble Andhra Pradesh High Court in the case of Vaveru Co-operative Rural Bank Ltd. v CIT [(2017) 396 ITR 371 took a view that such interest income is attributable to the activities of the society and, therefore, eligible for ex ..... X X X X Extracts X X X X X X X X Extracts X X X X
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