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TMI Blog2024 (7) TMI 874X X X X Extracts X X X X X X X X Extracts X X X X ..... essee cooperative society was eligible for deduction under section 80P(2)(d) in respect of gross interest received from cooperative bank without adjusting interest paid to said bank. Decided in favour of assessee. - SHRI PAWAN SINGH, JUDICIAL MEMBER For the Assessee represented : Shri Akshay Mitish Kumar Modi, C.A. For the Department represented : Shri Vinod Kumar, Sr. DR ORDER PER: PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the Revenue is directed against the order of National Faceless Appeal Centre, Delhi (NFAC)/learned Commissioner of Income Tax (Appeals) (in short, the ld. CIT(A)) dated 21/07/2023 for the Assessment Year (AY) 2014-15. The revenue has raised following grounds of appeal: 1. On the facts and circumstances of the cas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oner of Income-tax, Hubballi vs. Totagars Co-operative Sale Society. 5. On the basis of the facts and circumstances of the case and -in law, the Id. CIT(A) ought to have upheld the order of the Assessing Officer. 6. It is therefore prayed that the order of Id. CIT(A) may kindly be set aside that of the Assessing Officer be restored. 7. The appellant craves leave to add, alter, amend and/or withdraw any ground of appeal either before or during the course of hearing of the appeal. 2. Rival submissions of both the parties have been heard and record perused. The learned Senior Departmental Representative (ld. Sr. DR) for the revenue submit that the tax effect in this appeal in less than the threshold limit of tax effect of Rs. 50.00 lacs, howev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e parties and have gone through the orders of the authorities below. I find that the Assessing Officer made addition of Rs. 9,56,635/- by disallowing the deduction under Section 80P(2)(d) of the Act. Such income was earned by the assessee on fixed deposit with Surat District Cooperative Bank. I further find that before the ld. CIT(A), the assessee filed detailed written submissions as has been recorded in para 4.1 of his order. The ld. CIT(A) by following the decision of Hon'ble Gujarat High Court in Sabarkantha District Co-operative Milk Producers Union Ltd. Vs CIT in Tax Appeal no. 473 of 2014 and other decisions of Ahmedabad Tribunal, allowed relief to the assessee. The ld. CIT(A) held that the assessee has furnished evidence that Su ..... X X X X Extracts X X X X X X X X Extracts X X X X
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