https://www.taxtmi.com/caselaws?id=445354 ITAT Pune held that PCIT cannot exercise revision powers u/s 263 regarding exemption of interest income earned by cooperative society from deposits with other cooperative banks or banks. The Tribunal found this constitutes a debatable issue with divergent HC opinions on eligibility for exemption u/s 80P(2)(a)(i). Following Malabar Industrial Co. Ltd precedent, revision powers cannot be exercised on debatable matters. The Tribunal consistently held such interest income qualifies for deduction u/s 80P(2)(a)(i), making any remand futile. Appeal allowed. en-us Tue, 11 Jul 2023 00:00:00 +0530 Mon, 06 Nov 2023 10:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445354 ITAT Pune held that PCIT cannot exercise revision powers u/s 263 regarding exemption of interest income earned by cooperative society from deposits with other cooperative banks or banks. The Tribunal found this constitutes a debatable issue with divergent HC opinions on eligibility for exemption u/s 80P(2)(a)(i). Following Malabar Industrial Co. Ltd precedent, revision powers cannot be exercised on debatable matters. The Tribunal consistently held such interest income qualifies for deduction u/s 80P(2)(a)(i), making any remand futile. Appeal allowed. Case-Laws Income Tax Tue, 11 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445354