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Issues: Whether interest earned from deposits in nationalised banks was eligible for deduction under section 80P(2)(d) of the Income-tax Act, 1961.
Analysis: The claimed deduction was founded on section 80P(2)(d), which grants relief only in respect of interest or dividend derived by a co-operative society from its investments with another co-operative society. The interest in question was received from a nationalised bank, not from a co-operative society. The reliance placed on decisions dealing with section 80P(2)(a) was found inapplicable, since the present claim was not made under that provision and the factual foundation required for that line of authority was absent.
Conclusion: The interest income from the nationalised bank was not deductible under section 80P(2)(d), and the disallowance was upheld.
Ratio Decidendi: Deduction under section 80P(2)(d) is available only for interest or dividend from investments with another co-operative society, and not for interest earned from a nationalised bank.