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TMI Blog2023 (11) TMI 1277X X X X Extracts X X X X X X X X Extracts X X X X ..... eal is filed by the Assessee against order dated 23.03.2023 passed by the CIT(A)-11, Ahmedabad for the Assessment Year 2014-15. 2. The Assessee has raised the following grounds of appeal :- "1. The learned CIT(A)-11, Ahmedabad, has erred in law and on facts in upholding the disallowance made by the AO of the claim u/s. 80P(2)(d) of the Act, of Rs. 4,12,210/- thereby dismissing the appeal. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er VI-A of Income Tax Act, 1961. Notice u/s 143(2) of the Act was issued on 19.09.2016 which was duly served on assessee. The assessee filed details. The Assessing Officer observed that the assessee is a Co-operative Society and received interest from the Sa.Co. Bank (Rs.2,86,317/-), Dena Bank (Rs.47,879/-) as well as Saving Bank interest of Rs. 47,547/- and Rs. 30,472/- is not allowable ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - was received from S. K. Dist. Co-op Bank Ltd. and Rs. 47,879/- and Rs. 47,542/- was received from Dena Bank. The Ld. AR further submitted that the assessee is a Sharafi Mandali i.e. Credit Society carrying on the business of banking or providing credit facilities to its members and is therefore eligible for deduction u/s. 80P(2)(a)(i) of the Act for "the whole of the amount of profits ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ict Co-operative Banks cannot be treated at par with the business income of the assessee as it forms income from other sources. 7. Heard both the parties and perused all the relevant material available on record. It is pertinent to note that the assessee earned interest on Fixed Deposits from the S. K. District Co-operative Bank Ltd. as well as Dena Bank. As per the decision of Hon'ble Gujarat Hi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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