Section 80P exemption on interest income upheld where consistent precedents had already favoured the assessee.

ITAT Lucknow sustained exemption under section 80P on interest income from investments and fixed deposits because the identical issue had already been decided consistently in the assessee's favour, including in the assessee's own case. The Tribunal found that the Commissioner (Appeals) had followed those binding precedents and that the Revenue showed no infirmity in that approach. The Revenue's challenge therefore failed, and the allowance of exemption on the interest income was upheld.

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Issues: Whether the Revenue was entitled to challenge the allowance of exemption under section 80P of the Income-tax Act, 1961 on interest income earned from investments and fixed deposits.

Analysis: The Tribunal noted that the identical controversy had already been decided in favour of the assessee in earlier cases, including the assessee's own case, and that the Commissioner (Appeals) had followed those binding and consistent decisions. No infirmity in that approach was shown by the Revenue.

Conclusion: The allowance of exemption on the interest income was upheld and the Revenue's challenge failed.

Ratio Decidendi: Where an identical issue has already been consistently decided in favour of the assessee and the appellate order follows those decisions, the allowance of exemption under section 80P on the relevant interest income is to be sustained.

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