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    <title>2024 (11) TMI 971 - GUJARAT HIGH COURT</title>
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    <description>Interest earned by a co-operative society from investment with a co-operative bank remained deductible under section 80P(2)(d), because section 80P(4) limits the deduction claim of co-operative banks and does not rewrite clause (d) to exclude such income in the hands of a co-operative society. The court treated section 80P as a beneficial provision for the co-operative sector and held that a co-operative bank continues to fall within the relevant co-operative society context for clause (d). As the deduction was legally available, the Principal Commissioner could not invoke section 263, since the assessment order was neither erroneous nor prejudicial to the interests of the Revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=761985</link>
      <description>Interest earned by a co-operative society from investment with a co-operative bank remained deductible under section 80P(2)(d), because section 80P(4) limits the deduction claim of co-operative banks and does not rewrite clause (d) to exclude such income in the hands of a co-operative society. The court treated section 80P as a beneficial provision for the co-operative sector and held that a co-operative bank continues to fall within the relevant co-operative society context for clause (d). As the deduction was legally available, the Principal Commissioner could not invoke section 263, since the assessment order was neither erroneous nor prejudicial to the interests of the Revenue.</description>
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