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    <title>2023 (9) TMI 1687 - ITAT MUMBAI</title>
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    <description>A co-operative credit society that deals only with its members and does not hold an RBI banking licence remains eligible for deduction on income attributable to member credit facilities under section 80P(2)(a)(i). Income from deposits placed with other co-operative banks was treated as covered by section 80P(2)(d), and income from dealings with non-members had already been taxed. On that footing, section 80P(4) was held inapplicable to deny the benefit, and the Principal Commissioner had no valid basis to revise the assessment under section 263 as erroneous and prejudicial to the Revenue.</description>
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      <description>A co-operative credit society that deals only with its members and does not hold an RBI banking licence remains eligible for deduction on income attributable to member credit facilities under section 80P(2)(a)(i). Income from deposits placed with other co-operative banks was treated as covered by section 80P(2)(d), and income from dealings with non-members had already been taxed. On that footing, section 80P(4) was held inapplicable to deny the benefit, and the Principal Commissioner had no valid basis to revise the assessment under section 263 as erroneous and prejudicial to the Revenue.</description>
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