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    <title>2025 (6) TMI 2012 - GUJARAT HIGH COURT</title>
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    <description>Section 263 revision was not sustainable where the assessment had allowed deduction under section 80P(2)(d) on interest earned by a co-operative society from deposits with a co-operative bank. The analysis states that a co-operative bank is treated as a co-operative society for this purpose, section 80P is a beneficial provision to be construed liberally in favour of the assessee, and section 80P(4) does not by itself bar the deduction on such interest income. Because the assessment order accorded with the prevailing legal position, the statutory requirements of error and prejudice to the Revenue were not met, and revisionary jurisdiction could not be invoked.</description>
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      <link>https://www.taxtmi.com/caselaws?id=773899</link>
      <description>Section 263 revision was not sustainable where the assessment had allowed deduction under section 80P(2)(d) on interest earned by a co-operative society from deposits with a co-operative bank. The analysis states that a co-operative bank is treated as a co-operative society for this purpose, section 80P is a beneficial provision to be construed liberally in favour of the assessee, and section 80P(4) does not by itself bar the deduction on such interest income. Because the assessment order accorded with the prevailing legal position, the statutory requirements of error and prejudice to the Revenue were not met, and revisionary jurisdiction could not be invoked.</description>
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