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Issues: Whether interest income earned by a co-operative credit society from fixed deposits made with nationalised and commercial banks, in compliance with statutory requirements governing its funds, is assessable as business income so as to qualify for deduction under section 80P(2)(a)(i) of the Income-tax Act, 1961.
Analysis: The assessee was engaged exclusively in providing credit facilities to its members and was not a co-operative bank. Its surplus funds were parked in fixed deposits with banks in compliance with the mandatory investment requirements under the applicable co-operative society law. The interest income arose from such deployments of funds and was treated in earlier years as business income. The order also relied on the settled view that where investments are integrally connected with the business of a co-operative credit society, the resulting interest is attributable to that business and not assessable merely under the head income from other sources.
Conclusion: The interest income was held to be attributable to the assessee's business and eligible for deduction under section 80P(2)(a)(i); the disallowance was not sustained.
Ratio Decidendi: Interest earned by a co-operative credit society from deposits made as part of its statutory and business-linked deployment of funds is income attributable to its business and qualifies for deduction under section 80P(2)(a)(i).