9911796707
TMI Blog2024 (10) TMI 1621X X X X Extracts X X X X X X X X Extracts X X X X ..... perative banks . 2. ITA number 1063/M/2024 is filed by the assessee for assessment year 2017 - 18 against the appellate order passed by the National faceless appeal Centre, Delhi (the learned CIT - A) dated 31/1/2024 wherein the appeal filed by the assessee against the assessment order passed under section 143(3) of The Income Tax Act [ the Act] passed by The Income Tax Officer Ward 22(2)(7), Mumbai [ The ld. AO ] dated 14/12/2019 was partly allowed. 3. Still the grievance of the assessee is that the learned CIT - A has not allowed deduction under section 80P(2)(d) with respect to the interest income earned. 4. Brief facts of the case shows that the assessee is a cooperative credit society accepting deposits and lending money to the memb ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... st is received from cooperative societies. However, if the interest is received from schedule banks that has to be excluded from the deduction under that subsection. Accordingly appeal of the assessee was partly allowed. 6. The assessee is aggrieved with that order and is in appeal before us. 7. We have heard the rival contentions and perused the orders of the learned lower authorities. Undisputedly the fact shows that assessee is a cooperative credit society wherein it is eligible for deduction under section 80P(2)(a)(i) of its income arising from the business of providing credit facilities to its member, then whole of the amount of the profits and gains of such business are deductible under section 80P(2)(a)(i) of the act. Further under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... we find that all income of the assessee other than interest received from non-cooperative societies i.e., schedule banks or other banks which are not cooperative banks, is eligible for deduction under section 80P(2)(a)(i) or (d) of the act. 12. Accordingly, both the grounds of appeal raised by the assessee are allowed. 13. The appeal for assessment year also involves similar facts wherein the returned income of the assessee at rupees Nil was assessed at Rs. 5,926,620/- by denying deduction under section 80P of the act by assessment order dated 19/8/2021. When the matter reached before the learned CIT - A he held that assessee is eligible for deduction under the section but has directed the learned assessing officer to verify if the incom ..... X X X X Extracts X X X X X X X X Extracts X X X X
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