Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Interest earned on short-term bank deposits of surplus funds retained its character as income attributable to the business of providing credit facilities to members, so it qualified for deduction under section 80P(2)(a)(i). Applying Tumkur Merchants Souharda Credit Cooperative Ltd., the Tribunal held that temporary investment of funds not immediately required for lending does not convert such interest into income from other sources. It also distinguished the Totgars decisions, noting they concerned section 80P(2)(d) and were not governing on the facts. The lower authorities' denial of deduction was held erroneous, and the deduction was directed to be allowed.
Interest earned on short-term bank deposits of surplus funds retained its character as income attributable to the business of providing credit facilities to members, so it qualified for deduction under section 80P(2)(a)(i). Applying Tumkur Merchants Souharda Credit Cooperative Ltd., the Tribunal held that temporary investment of funds not immediately required for lending does not convert such interest into income from other sources. It also distinguished the Totgars decisions, noting they concerned section 80P(2)(d) and were not governing on the facts. The lower authorities' denial of deduction was held erroneous, and the deduction was directed to be allowed.
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