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Issues: Whether interest and dividend received by a cooperative society from a cooperative bank registered under the Co-operative Societies Act are eligible for deduction under Section 80P(2)(d) of the Income-tax Act, 1961.
Analysis: The question was examined in the light of decisions of the jurisdictional High Court recognizing entitlement to deduction under Section 80P(2)(d) for interest received from cooperative banks registered under the Co-operative Societies Act. The authorities relied upon establish that income in the form of interest and dividend received from such cooperative banks falls within the scope of Section 80P(2)(d) as applicable to cooperative societies.
Conclusion: Deduction under Section 80P(2)(d) of the Income-tax Act, 1961 is allowable in respect of interest and dividend received from a cooperative bank registered under the Co-operative Societies Act; result is in favour of the assessee.
Ratio Decidendi: Interest and dividend received by a cooperative society from a cooperative bank registered under the Co-operative Societies Act fall within the scope of deduction under Section 80P(2)(d) of the Income-tax Act, 1961 as affirmed by the jurisdictional High Court.