Deduction for co-operative society investment income upheld only to the extent supported by binding precedent; locker rent claim failed.

Income from statutory investments made under the co-operative societies law was treated as falling within the existing precedent on deduction under Section 80P(2)(a)(i), and the Tribunal's view was found consistent with that binding authority. The related claim for deduction on investment income was therefore not reopened, and the challenge did not survive. The accompanying claim relating to locker rent was also not accepted. On that basis, the questions were answered against the assessee and in favour of the Revenue, and the appeal was dismissed.

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Issues: Whether deduction under Section 80P(2)(a)(i) of the Income-tax Act, 1961 was available in respect of income from investment of reserve funds and statutory reserves, and whether locker rent was eligible for the same deduction.

Analysis: The appeal was governed by the existing decision that interest income from statutory investments made in accordance with the co-operative societies law was eligible for deduction under Section 80P(2)(a)(i). The Tribunal's view was held to be in line with that binding precedent, and the matter was treated as settled. The challenge to the related claim for deduction therefore did not survive.

Conclusion: The questions were answered against the assessee and in favour of the Revenue; the claimed deduction was not disturbed in the Revenue's favour, and the appeal failed.

Final Conclusion: The appeal was dismissed on the basis that the issue stood concluded by prior authority and the impugned order required no interference.

Ratio Decidendi: Income derived from statutory investments made under the applicable co-operative societies law is eligible for deduction under Section 80P(2)(a)(i) only to the extent recognised by binding precedent.

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