TMI Blog2024 (8) TMI 1076X X X X Extracts X X X X X X X X Extracts X X X X ..... oney to its Members - HELD THAT:- On perusal of provisions of section 80P(2)(d), it is clear that the income derived by a cooperative society from its investment held with other cooperative societies shall be exempt from the total income of a cooperative society. Therefore, what is relevant for claiming of deduction u/s 80P(2)(d) is that interest income should have been derived from the investment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd allowed. X X X X Extracts X X X X X X X X Extracts X X X X ..... me' u/s. 56 of the Act. 3. Being aggrieved by the above disallowance, an appeal was filed before the CIT(A)/NFAC who vide impugned order confirmed the action of the AO. 4. Being aggrieved, the appellant is in appeal before the Tribunal. 5. I heard the rival submissions and carefully perused the material on record. The issue in the present appeal relates to the allowability of deduction u/s. 80P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ety with any other cooperative society. This issue was considered by the Hon'ble Karnataka High Court in the case of CIT vs. Totagars Cooperative Sale Society, 392 ITR 74 (Karn) wherein the Hon'ble High Court after referring to the decision of the Hon'ble Supreme Court in the case of Totgar's Co-operative Sale Society Ltd.Vs. ITO (2010) 322 ITR 283(SC) held that the ratio of decision of the Hon'bl ..... X X X X Extracts X X X X X X X X Extracts X X X X
|