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    <title>2026 (7) TMI 554 - ITAT KOLKATA</title>
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    <description>Interest earned by a credit co-operative society on surplus funds placed with co-operative and scheduled banks was treated as attributable to its business activity, not as income from other sources, so it qualified for deduction under section 80P(2)(a)(i). The analysis notes that the deposits were from surplus funds, not amounts due to members or liabilities owed to them, and relies on prior authorities supporting deduction in such circumstances. It also applies consistency, observing that the Revenue had accepted the same position in earlier years and should not depart from that view absent a change in facts. The disallowance was therefore set aside in favour of the assessee.</description>
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      <description>Interest earned by a credit co-operative society on surplus funds placed with co-operative and scheduled banks was treated as attributable to its business activity, not as income from other sources, so it qualified for deduction under section 80P(2)(a)(i). The analysis notes that the deposits were from surplus funds, not amounts due to members or liabilities owed to them, and relies on prior authorities supporting deduction in such circumstances. It also applies consistency, observing that the Revenue had accepted the same position in earlier years and should not depart from that view absent a change in facts. The disallowance was therefore set aside in favour of the assessee.</description>
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