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TMI Blog2024 (4) TMI 935X X X X Extracts X X X X X X X X Extracts X X X X ..... for deduction u/s 80P(2)(a)(i) of the Act. Reliance in this regard can also be placed on the decision of Quepem Urban Co-operative Credit Society Ltd [ 2021 (5) TMI 406 - BOMBAY HIGH COURT] . 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 - 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 Hon ble Karnataka High Court in the case of Tumkur Merchants Souharda Credit Cooperative Ltd. [ 2015 (2) TMI 995 - KARNATAKA HIGH COURT ] The interest income earned on fixed deposits with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nst the income of Rs. 70,503/- assessed u/s. 143(3) of the Act.. While doing so, the Assessing Officer had brought to tax the interest earned on Fixed Deposits with Bank of Maharashtra holding that the said interest does not qualify for deduction u/s 80P(2)(a)(i) of the Act. 4. Being aggrieved, an appeal was filed before the NFAC, who vide impugned order confirmed the action of the Assessing Officer. 5. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 6. The ld. AR submitted before me that the issue no more res integra by virtue of several decisions passed by the Pune Benches of the Tribunal in favour of the appellant(s). 7. On the other hand, ld. Sr. DR placing reliance on the orders of the lower auth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rt in the case of Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT 50 taxmann.com 278, the Hon ble Punjab Haryana High Court in the case of CIT Vs. Punjab State Cooperative Agricultural Development Bank Ltd. 389 ITR 68 and the Hon ble Kolkata High Court in the case of CIT Vs. Southern Eastern Employees Cooperative Credit Society Ltd. 390 ITR 524 took a view that the income arising on the surplus invested in short term deposits and securities cannot be attributed to the activities of the society and, therefore, not eligible for exemption u/s. 80P(2)(a)(i) of the Act. However, the Hon ble Karnataka High Court in the case of Tumkur Merchants Souharda Credit Co-operative Ltd. Vs. ITO (2015) 230 taxmann.com 309 (Kar.) and the Hon ble Telan ..... X X X X Extracts X X X X X X X X Extracts X X X X
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