2017 (3) TMI 146

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....Nos.5889- 90/2017, ITA 156/2017 & CM Nos.5891- 92/2017, ITA 157/2017 - -<br>Income Tax<br>MR. S. RAVINDRA BHAT & MR. NAJMI WAZIRI JJ. Mr. P. Roy Choudhuri and Ms. Vibhooti Malhotra, Advocates for Revenue. Mr. Gaurav Jain, Advocate for Respondent. O R D E R CM Nos.5880, 5882, 5884, 5886, 5889, 5891, 5893 & 6031 of 2017 (for exemption) 1. Allowed, subject to all just exceptions. 2.....

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....Society, which mobilises savings from its members. 4. The issue arose in 2008-09 and 2009-10. In 2008-09, it reported Rs. 1,44,04,060/- as gross income to claim benefit of Section 80 P of the Act. It is not in dispute that the income derived by the assessee was eligible for deduction under Section 80P(2)(d) of the Act as it arose from investment in respect of income derived from investment in o....

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....ch, as in this case, all its expenditure incurred for deriving an income vis-a-vis investing in Cooperative Societies (i.e. which resulted in the income deductible under Section 80P). The ITAT after considering the rival submissions held as follows:- &nbsp; "11. We have perused the orders passed by the authorities below and the judgment relied upon by the assessee. It is not in dispute that the....

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....from other sources; no expenditure could be allowed at all. 6. This Court is of the opinion that the ITAT's reasoning cannot be faulted. Concededly the nature of the activities i.e. that which resulted in income under Section 80P and that which resulted in income from other sources are identical. This involves the collection, deposits and management of funds from the assessee's subscribers/memb....