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ITAT held that deduction under section 80P(2)(d) is not allowable for interest income earned from investments with cooperative banks. The tribunal ruled that exemption provisions must be strictly interpreted and distinguished cooperative banks from cooperative societies per se. Relying on Karnataka High Court precedents in Bangalore Club and Totagars cases, which followed Supreme Court judgment, ITAT determined that cooperative banks are treated at par with scheduled banks under sub-section (4) of section 80P. The deduction is available only for interest received from cooperative societies, not cooperative banks. Revenue's appeal was allowed, CIT(A)'s order was set aside, and AO's order was confirmed.
ITAT held that deduction under section 80P(2)(d) is not allowable for interest income earned from investments with cooperative banks. The tribunal ruled that exemption provisions must be strictly interpreted and distinguished cooperative banks from cooperative societies per se. Relying on Karnataka High Court precedents in Bangalore Club and Totagars cases, which followed Supreme Court judgment, ITAT determined that cooperative banks are treated at par with scheduled banks under sub-section (4) of section 80P. The deduction is available only for interest received from cooperative societies, not cooperative banks. Revenue's appeal was allowed, CIT(A)'s order was set aside, and AO's order was confirmed.
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