Interest earned by a co-operative society on fixed deposits...

Interest earned by a co-operative society on fixed deposits placed with banks from amounts representing share capital and statutorily mandated reserve funds was held to be "attributable to" its eligible business for purposes of deduction under section 80P(2)(a)(iii). Since the society was legally obliged under the applicable co-operative societies law and rules to maintain a minimum reserve fund and invest such funds, the deposits could not be treated as investments from surplus or non-business funds, and the Revenue did not dispute the statutory compulsion. Accordingly, the interest income qualified for deduction under section 80P(2)(a)(iii), and the assessee's appeal was allowed. - ITAT