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ITAT held that the assessee had not claimed deduction under s.80P, so no disallowance arose; however, because the assessee is a co-operative bank under liquidation with substantial statutory liabilities (including under the DICGC and relevant co-operative legislation) that may negate any real accrual of income, the tribunal applied the real-income principle. ITAT set aside the impugned orders of the ld. CIT(A) for all three assessment years and restored the matters to the file of the AO for de novo assessment, directing verification of whether any income has in reality accrued or arisen to the assessee; appeals by the assessee were allowed for statistical purposes.
ITAT held that the assessee had not claimed deduction under s.80P, so no disallowance arose; however, because the assessee is a co-operative bank under liquidation with substantial statutory liabilities (including under the DICGC and relevant co-operative legislation) that may negate any real accrual of income, the tribunal applied the real-income principle. ITAT set aside the impugned orders of the ld. CIT(A) for all three assessment years and restored the matters to the file of the AO for de novo assessment, directing verification of whether any income has in reality accrued or arisen to the assessee; appeals by the assessee were allowed for statistical purposes.
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