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    <title>2017 (5) TMI 722 - ITAT AHMEDABAD</title>
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    <description>Interest earned by a co-operative credit society on fixed deposits of surplus funds is taxable as income from other sources, because it arises from deployment of idle funds and not from the provision of credit facilities to members. Although the society was found to be carrying on member-based lending activity and was not treated as a banking business for the purpose of exclusion under section 80P(4), the deposit interest did not qualify as business income attributable to its operations. Applying the Totgars principle, the interest was brought to tax under section 56 and no substantiated expenditure was shown against that income, so deduction under section 80P was denied.</description>
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      <link>https://www.taxtmi.com/caselaws?id=342984</link>
      <description>Interest earned by a co-operative credit society on fixed deposits of surplus funds is taxable as income from other sources, because it arises from deployment of idle funds and not from the provision of credit facilities to members. Although the society was found to be carrying on member-based lending activity and was not treated as a banking business for the purpose of exclusion under section 80P(4), the deposit interest did not qualify as business income attributable to its operations. Applying the Totgars principle, the interest was brought to tax under section 56 and no substantiated expenditure was shown against that income, so deduction under section 80P was denied.</description>
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