2010 (7) TMI 296

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....Deepak Gupta, J. In this appeal filed by the revenue it is urged that the following substantial questions of law arise for decision:- "1. Whether the assessee cooperative bank was entitled to deduction under Section 80P(2)(a)(i) of the Income-tax Act in respect of interest earned on deposits of non-SLR and surplus funds in non statutory reserves, even though the income so earned can not be s....

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....n which arises is whether the income earned on account of interest on deposits made out of the non SLR funds can be said to be attributable to the banking activities of the bank. There can be no dispute with the preposition that the word attributable is much wider in scope than derived. The Legislature has used the words "attributable to" in conjunction with the phrase "any one or more of such act....