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    <description>Interest earned by a credit co-operative society on deposits with banks and co-operative societies was treated as attributable to its credit business because the funds were surplus working capital not immediately required for lending to members. The broader expression &quot;attributable to&quot; was applied in preference to the narrower &quot;derived from&quot;, so the receipts formed part of the profits and gains of the business of providing credit facilities. As the deposits were not mere liabilities or amounts due to members, the contrary classification as income from other sources was not accepted, and deduction under section 80P(2)(a)(i) was allowed.</description>
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