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2023 (6) TMI 257

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..... ture of the said miscellaneous income, but could not get satisfactory reply, as a result of which, treated it as income from other sources - HELD THAT:- Miscellaneous income mainly constitutes grant received from the West Bengal Government for various activities as per its registered bye-laws. No reason to treat any of the element of miscellaneous income enumerated above as income from other sources. Since the alleged sum is the income earned by the Society for the purpose of its objects, the same is eligible for deduction under section 80P - Decided in favour of assessee. - Shri Rajpal Yadav, Vice-President And Dr. Manish Borad, Accountant Member Shri Himangshu Kr. Ray, Shri Paban Kr. Ray Smt. Sangita Paul, Advocate, appeared on .....

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..... to this are that the assessee, which is a Cooperative Society, formed by its Tribal members and registered under the West Bengal Cooperative Societies Act, 1973 having Registration No. 69-WD of 1976, is engaged in providing Mini Bank service to its members, Sales of Fertilizer to its Tribal members as per bye-laws, guidelines of Government of West Bengal. In the return of income filed on 26.03.2018 for A.Y. 2017-18, deduction under section 80P has been claimed at Rs.65,844/-. During the course of complete scrutiny under CASS, ld. Assessing Officer noticed that in the Profit Loss Account, the assessee has claimed miscellaneous income of Rs.9,92,664.28. The ld. Assessing Officer confronted the assessee to explain the nature of the said mis .....

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..... 5 BOD Honorarium from Govt. 27,600.00 6 Adibasi cultural progm. Grant 32,700.00 7 Arrear salary grant 1,23,856.00 8 Training T.A cost received 35,395.00 TOTAL RS. 9,92,664.00 8. Before us, it has been contended by the ld. Counsel for the assessee that all the above-referred heads of miscellaneous income are part and parcel of the regular activities carried out by the assessee-Society for its Tribal members and cannot be held to be the income from other sources. We have given .....

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