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TMI Blog2024 (9) TMI 1268X X X X Extracts X X X X X X X X Extracts X X X X ..... ome was earned on deposits made with a Cooperative Bank. 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 deri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , Accountant Member For the Assessee : Shri Pramod Shingte For the Revenue : Shri Rajesh Gawali ORDER PER INTURI RAMA RAO, AM: This is an appeal filed by the assessee directed against the order of Addl./JCIT(A)-1, Lucknow dated 19.03.2024 for the assessment year 2021-22. 2. Brief facts of the case are as under : The appellant is a Primary Credit Cooperative Society registered under the Maharashtra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lacing reliance on the judgment of Hon ble Apex Court in the case of Totgar s Cooperative Sale Society Ltd. Vs. ITO (2010 322 ITR 283 (SC) and the judgment of Hon ble Karnataka High Court in the case of PCIT Ors Vs. Totagars Cooperative Sale Society confirmed the action of CPC denying the deduction u/s. 80P(2)(d) of the Act claimed at Rs. 5,57,630/-. 4. Being aggrieved, the appellant is in appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tive 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 made by the assessee cooperative society 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 aft ..... X X X X Extracts X X X X X X X X Extracts X X X X
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