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Issues: Whether interest income earned from deposits with a cooperative bank registered as a cooperative society is eligible for deduction under section 80P(2)(d), and whether the objection to production of the registration certificate as additional evidence could defeat the claim.
Analysis: The deduction under section 80P(2)(d) is available to a cooperative society in respect of income by way of interest or dividend derived from investments with any other cooperative society. The assessee produced a certificate from the Registrar of Cooperative Societies showing that the recipient bank was registered as a cooperative society. The objection that this certificate was additional evidence was rejected because it was an official public document and its authenticity was not in doubt. Once the recipient institution was established to be a cooperative society, the interest earned from its deposits fell within section 80P(2)(d). The view was supported by the cited coordinate bench and High Court authorities treating a cooperative bank as a cooperative society for this purpose.
Conclusion: The interest income was deductible under section 80P(2)(d), and the disallowance made by the Assessing Officer and sustained by the first appellate authority was unsustainable.
Ratio Decidendi: For the purpose of section 80P(2)(d), interest earned by a cooperative society from investments with a cooperative bank that is itself a cooperative society is deductible in full, and a valid official certificate proving such status cannot be rejected merely as additional evidence.