9911796707
TMI Blog2024 (5) TMI 28X X X X Extracts X X X X X X X X Extracts X X X X ..... DER PER INTURI RAMA RAO, AM: This is an appeal filed by the assessee directed against the order of National Faceless Appeal Centre, Delhi (NFAC) dated 08.11.2023 for the assessment year 2020-21. 2. Brief facts of the case are that the appellant is a Co-operative credit society engaged in providing credit facilities to its members. The Return of Income for the assessment year 2020-21 was filed o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... P of the Act. 3. Being aggrieved, an appeal was filed before the NFAC, who vide impugned order restricted the disallowance to the tune of Rs. 23,42,047/- as against the entire disallowance of Rs. 1,16,19,383/- made by the AO. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. The ld. AR submitted before us that the issue no more res integra by virtue o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee is eligible for deduction u/s 80P(2)(a)(i) of the Act. Reliance in this regard can also be placed on the decision of the Hon'ble Bombay High Court in the case of PCIT vs. Quepem Urban Co-operative Credit Society Ltd., 438 ITR 631 (Bom.). 8. As regards, the issue as to the allowability of exemption under the provisions of section 80P(2)(a)(i) in respect of interest income earned by a coo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ive 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 Cooperative Ltd. Vs. ITO (2015) 230 taxmann.com 3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing the judgment of Hon'ble Karnataka High Court in the case of Tumkur Merchants Souharda Credit Co-operative Ltd. (supra). Following the decision of the Coordinate Bench of the Tribunal, we of the considered opinion that the interest income earned on fixed deposits with cooperative bank/scheduled bank partakes character of the business income, which is eligible for deduction u/s 80P(2)(a)(i) of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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