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    <title>2025 (12) TMI 1883 - ITAT BANGALORE</title>
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    <description>Interest earned by a credit co-operative society from surplus funds temporarily invested with co-operative societies qualifies for deduction under Section 80P(2)(a)(i) when the funds are attributable to its business of providing credit facilities to members and are not liabilities payable to members. The expression &quot;attributable to&quot; has wider scope than &quot;derived from&quot;, allowing deduction for interest on funds not immediately required for lending. Interest arising from member liabilities is distinguishable. Delay in filing appeals may be condoned where appellate orders were sent to a superseded email address, the taxpayer did not receive them, and appeals were filed promptly after discovery.</description>
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      <description>Interest earned by a credit co-operative society from surplus funds temporarily invested with co-operative societies qualifies for deduction under Section 80P(2)(a)(i) when the funds are attributable to its business of providing credit facilities to members and are not liabilities payable to members. The expression &quot;attributable to&quot; has wider scope than &quot;derived from&quot;, allowing deduction for interest on funds not immediately required for lending. Interest arising from member liabilities is distinguishable. Delay in filing appeals may be condoned where appellate orders were sent to a superseded email address, the taxpayer did not receive them, and appeals were filed promptly after discovery.</description>
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