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2024 (8) TMI 1076

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..... is an appeal filed by the assessee directed against the order of National Faceless Appeal Centre, Delhi dated 31.03.2024 for the assessment year 2020-21. 2. Brief facts of the case are as under : The appellant is a Primary Credit Cooperative Society registered under the Maharashtra Cooperative Societies Act, 1960. It is engaged in the business of providing credit facilities to its Members. The R .....

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..... eing 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(2)(a)(i)/80P(2)(d) in respect of interest income earned by a Cooperative Society formed with the object of accepting deposits from Members and lending money to its Members, w .....

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..... n) 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'ble Supreme Court is not to be applicable in respect of interest income on investment as same falls under the provisions of section 80P(2)(d) and not u/s 80P(2)(a)(i) of the Act .....

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