Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
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Interest earned by a co-operative society from investments with a co-operative bank was treated as eligible for deduction under section 80P(2)(d), following earlier non-jurisdictional precedent. Where conflicting non-jurisdictional High Court views exist, the view favourable to the assessee was preferred. Reliance on Totgars was not accepted to deny the claim in this context. The disallowance was deleted in principle, but the Assessing Officer was asked to verify the actual nature of the interest and then grant consequential relief.
Interest earned by a co-operative society from investments with a co-operative bank was treated as eligible for deduction under section 80P(2)(d), following earlier non-jurisdictional precedent. Where conflicting non-jurisdictional High Court views exist, the view favourable to the assessee was preferred. Reliance on Totgars was not accepted to deny the claim in this context. The disallowance was deleted in principle, but the Assessing Officer was asked to verify the actual nature of the interest and then grant consequential relief.
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