Tribunal allows deductions for commission and interest income, integral to business activities.

The appeals were allowed for A.Y. 2017-18 and A.Y. 2018-19, granting deductions for commission income and interest income related to activities with MSEDCL. The Tribunal considered the income sources integral to the business activities of the assessee, following precedents to allow deductions under u/s.80P(2).

---

---

Issues:
- Denial of deduction u/s.80P(2)(a)(i) for commission income and interest income from Maharashtra State Electricity Distribution Company Limited (MSEDCL).
- Denial of deduction u/s.80P(2) on interest income from security deposit with MSEDCL.
- Denial of deduction u/s.80P(2)(a)(i) for commission income earned from MSEDCL bill collection.

Analysis:

A.Y. 2017-18:
- The assessee contested the denial of deduction u/s.80P(2)(a)(i) for commission income of Rs. 60,363 and interest income of Rs. 20,000 from MSEDCL. The AO disputed the allowability of deduction on various income sources, including commission income and interest income. The CIT(A) accepted deduction for some income but disapproved the claim for commission income and interest from MSEDCL.
- The Tribunal considered the precedent set by a previous order where commission income from MSEDCL was allowed as a deduction under u/s.80P(2)(a). As the commission income was related to the business activity of the assessee, it was held eligible for deduction. Similarly, the interest income on the security deposit with MSEDCL was also considered part of the business activity and granted deduction under u/s.80P(2).

A.Y. 2018-19:
- The sole issue in this appeal was the denial of deduction u/s.80P(2)(a)(i) for commission income of Rs. 2,36,160 earned from MSEDCL bill collection. The AO and CIT(A) had denied the deduction based on their previous views.
- The Tribunal noted that the issue regarding commission income from MSEDCL bill collection was the same as in the previous year. Following the decision for the earlier year, the deduction u/s.80P(2)(a) was allowed for the commission income earned from MSEDCL bill collection.

In conclusion, both appeals were allowed, and deductions were granted for the commission income and interest income related to MSEDCL activities for the respective assessment years. The Tribunal relied on precedents and the nature of the income sources being integral to the business activities of the assessee to allow the deductions under u/s.80P(2).

---