https://www.taxtmi.com/caselaws?id=775039 The ITAT PUNE-AT allowed the assessee's appeal against the PCIT's revision order u/s 263 regarding deduction u/s 80P on interest income. The PCIT contended that the AO erroneously allowed the deduction without proper inquiry into whether the interest income qualified as business income, and argued that cooperative banks cannot be treated as cooperative societies for s.80P(2)(d) purposes. The Tribunal relied on the coordinate bench decision in Talegaon Nagari Sahakari Patsanstha Limited, which held that interest income earned by cooperative societies on deposits with cooperative and scheduled banks qualifies for deduction under s.80P(2)(a)(i) and 80P(2)(d). The Tribunal found that while the AO's order may be prejudicial to revenue, it was not erroneous since the AO took a plausible view after considering the assessee's reply. Since both twin conditions for s.263 jurisdiction were not fulfilled, the PCIT's revision order was set aside. en-us Thu, 03 Jul 2025 00:00:00 +0530 Fri, 18 Jul 2025 08:22:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775039 The ITAT PUNE-AT allowed the assessee's appeal against the PCIT's revision order u/s 263 regarding deduction u/s 80P on interest income. The PCIT contended that the AO erroneously allowed the deduction without proper inquiry into whether the interest income qualified as business income, and argued that cooperative banks cannot be treated as cooperative societies for s.80P(2)(d) purposes. The Tribunal relied on the coordinate bench decision in Talegaon Nagari Sahakari Patsanstha Limited, which held that interest income earned by cooperative societies on deposits with cooperative and scheduled banks qualifies for deduction under s.80P(2)(a)(i) and 80P(2)(d). The Tribunal found that while the AO's order may be prejudicial to revenue, it was not erroneous since the AO took a plausible view after considering the assessee's reply. Since both twin conditions for s.263 jurisdiction were not fulfilled, the PCIT's revision order was set aside. Case-Laws Income Tax Thu, 03 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775039