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Revenue's Appeal Dismissed on Section 80P Deduction Disallowance The appeal was filed by the revenue against the order of the CIT(A) regarding the disallowance of deduction under section 80P(2)(a)(i) of the IT Act for ...
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Revenue's Appeal Dismissed on Section 80P Deduction Disallowance
The appeal was filed by the revenue against the order of the CIT(A) regarding the disallowance of deduction under section 80P(2)(a)(i) of the IT Act for the assessment year 2007-08. The CIT(A) had deleted the disallowance, allowing the deduction for the cooperative society providing credit facilities to members. The revenue argued for reversal based on the amendment inserting sub-section (4) of section 80P, but the appellate authority upheld the CIT(A)'s decision, stating that the cooperative society was eligible for the deduction under section 80P(2)(a)(i) as it was not a cooperative bank. The revenue's appeal was dismissed.
Issues involved: Appeal against order of CIT(A) regarding disallowance of deduction u/s 80P(2)(a)(i) of the IT Act for assessment year 2007-08.
Summary: 1. The revenue appealed against the CIT(A)'s order deleting the disallowance of deduction u/s 80P(2)(a)(i) of the Act amounting to Rs. 13,25,411. 2. The assessee, a cooperative society providing credit facilities to members, filed its return for the assessment year 2007-08. The AO reopened the assessment u/s 147 and disallowed the deduction u/s 80P(2)(a)(i) based on the amendment inserting sub-section (4) of section 80P. 3. The CIT(A) considered relevant case laws, CBDT Circular, and RBI High Level Committee report, and deleted the disallowance, stating that the appellant is entitled to deduction u/s 80P(2) despite not being covered by section 80P(4). 4. The revenue appealed, arguing that the CIT(A)'s decision should be reversed based on the insertion of sub-section (4) of section 80P. 5. The AR relied on the CIT(A)'s order and cited a case where it was held that a cooperative credit society is entitled to deduction u/s 80P(2)(a)(i) as it is not the same as a cooperative bank. 6. After hearing both sides, it was concluded that the assessee, being a cooperative society and not a cooperative bank, is eligible for deduction u/s 80P(2)(a)(i) of the Act. 7. Consequently, the appeal of the revenue was dismissed.
Order pronounced on 07-03-2013.
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