https://www.taxtmi.com/caselaws?id=448635 ITAT Mumbai held that reopening of assessment under Section 147 was invalid as no tangible material existed to justify reopening beyond four years, constituting mere reappraisal of facts. The tribunal ruled that assessee, being a credit cooperative society and not a cooperative bank, was eligible for deduction under Section 80P(2)(d) on interest income from cooperative banks. The AO erroneously treated assessee as primary cooperative bank without basis. Following SC precedents in Kerala State Cooperative Agricultural Rural Development Bank Ltd and Mavilayi Service Cooperative Bank Ltd, the tribunal allowed the appeal and directed grant of Section 80P(2)(d) deduction. en-us Mon, 22 Jan 2024 00:00:00 +0530 Wed, 24 Jan 2024 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448635 ITAT Mumbai held that reopening of assessment under Section 147 was invalid as no tangible material existed to justify reopening beyond four years, constituting mere reappraisal of facts. The tribunal ruled that assessee, being a credit cooperative society and not a cooperative bank, was eligible for deduction under Section 80P(2)(d) on interest income from cooperative banks. The AO erroneously treated assessee as primary cooperative bank without basis. Following SC precedents in Kerala State Cooperative Agricultural Rural Development Bank Ltd and Mavilayi Service Cooperative Bank Ltd, the tribunal allowed the appeal and directed grant of Section 80P(2)(d) deduction. Case-Laws Income Tax Mon, 22 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448635