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Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review. 
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Issues: Whether the appellant cooperative housing society is entitled to deduction under Section 80P(2)(d) of the Income-tax Act, 1961 in respect of interest earned on fixed deposits.
Analysis: The question requires application of Section 80P(2)(d) of the Income-tax Act, 1961 to interest income earned by the cooperative housing society on fixed deposits. The legal framework includes the statutory text of Section 80P(2)(d) of the Income-tax Act, 1961 and authoritative precedent, particularly the decision in Mavilayi Service Cooperative Bank Ltd. (431 ITR 1) of the Hon'ble Supreme Court, together with consistent decisions of coordinate benches of the Tribunal. These authorities establish that interest income of the nature earned by the appellant falls within the scope of deduction under Section 80P(2)(d) of the Income-tax Act, 1961.
Conclusion: The deduction under Section 80P(2)(d) of the Income-tax Act, 1961 is allowable in favour of the appellant; the addition made by the assessing officer is deleted and the appeal is allowed.
Ratio Decidendi: Section 80P(2)(d) of the Income-tax Act, 1961 permits deduction for the relevant interest income earned by a cooperative society, as affirmed by the Supreme Court in Mavilayi Service Cooperative Bank Ltd., and such precedent governs the present dispute.