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The HC held that the provisions of Section 80P(2)(d) would apply to the interest earned by the assessee cooperative society from the Surat District Cooperative Bank Ltd. The PCIT was not justified in invoking revisionary powers u/s 263, as the Tribunal rightly allowed deduction u/s 80P(2)(d) following binding precedents. The twin conditions for invoking Section 263 of erroneous assessment prejudicial to revenue were not fulfilled. The HC decided in favor of the assessee.
The HC held that the provisions of Section 80P(2)(d) would apply to the interest earned by the assessee cooperative society from the Surat District Cooperative Bank Ltd. The PCIT was not justified in invoking revisionary powers u/s 263, as the Tribunal rightly allowed deduction u/s 80P(2)(d) following binding precedents. The twin conditions for invoking Section 263 of erroneous assessment prejudicial to revenue were not fulfilled. The HC decided in favor of the assessee.
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