https://www.taxtmi.com/caselaws?id=752962 A pre-existing exemption notification under the repealed Income-tax Act, 1922 was held to cease to operate only to the extent the Income-tax Act, 1961 made specific provision for co-operative societies. Section 80P therefore displaced Notification No. SRO 1800 in that field, and exemption had to be tested under section 80P rather than as a separate surviving notification. The Tribunal also applied the High Court view that exemption, deduction and rebate provisions are tax incentives and cannot be read as independently coexisting on the same subject. On the facts, the assessee failed to show that its income arose from members or that mutuality was established, so exemption was denied. en-us Mon, 20 May 2024 00:00:00 +0530 Wed, 22 May 2024 06:56:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752962 A pre-existing exemption notification under the repealed Income-tax Act, 1922 was held to cease to operate only to the extent the Income-tax Act, 1961 made specific provision for co-operative societies. Section 80P therefore displaced Notification No. SRO 1800 in that field, and exemption had to be tested under section 80P rather than as a separate surviving notification. The Tribunal also applied the High Court view that exemption, deduction and rebate provisions are tax incentives and cannot be read as independently coexisting on the same subject. On the facts, the assessee failed to show that its income arose from members or that mutuality was established, so exemption was denied. Case-Laws Income Tax Mon, 20 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752962