2012 (11) TMI 591

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ent(s): Mr. Ramakant Sharma, Advocate. Deepak Gupta, J. Both these appeals are disposed of by a common judgment since common questions of law are involved in these appeals. 2. The appeals were admitted on the following questions of law: "1. Whether on the facts and in the circumstances of the case the ITAT was right in law in holding that the assessee bank was entitled to deduction u/s 80P (2) ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d. versus Commissioner of Income-tax, Gujarat-II, (1978) 113 ITR 84; Commissioner of Income-tax versus Karnataka State Cooperative Apex Bank, (2001) Vol. 251 ITR 194 and Mehsana District Central Cooperative Bank Ltd. versus Income-tax Officer, (2001) Vol. 251 ITR 522, this Court held as follows: "On the basis of the aforesaid observation of the Apex Court it is contended that we should remand the....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ey earn no income. The question 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 phras....