Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
Interest earned from deposits placed with co-operative banks was held eligible for deduction because a co-operative bank was treated as a co-operative society for section 80P(2)(d). Revenue's reliance on Totgar's Co-operative Sale Society Ltd. was rejected as distinguishable on facts, since that precedent did not concern deposits with a co-operative society. On that basis, the disallowance made by the first appellate authority could not stand. The same reasoning was applied to the other two assessment years on identical facts, and deduction was allowed for all three years.
Interest earned from deposits placed with co-operative banks was held eligible for deduction because a co-operative bank was treated as a co-operative society for section 80P(2)(d). Revenue's reliance on Totgar's Co-operative Sale Society Ltd. was rejected as distinguishable on facts, since that precedent did not concern deposits with a co-operative society. On that basis, the disallowance made by the first appellate authority could not stand. The same reasoning was applied to the other two assessment years on identical facts, and deduction was allowed for all three years.
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