2019 (4) TMI 505

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....ectively. The assessee also filed appeal for the assessment year 2015-16 against the order of the ld. CIT(A), Puducherry dated 15.03.2018. First, we shall take the appeals filed by the assessee. I.T.A. Nos. 1844, 735 & 1782/Chny/2018 [A.Y. 2013-14, 14-15 & 15-16] 2. The only effective ground raised in all the appeals of the assessee is that the ld. CIT(A) has erred in confirming the addition made towards interest income earned by the assessee and claimed deduction under section 80(P)(2) of the Income Tax Act, 1961 ["Act" in short]. 2. 1 The appeal filed by the assessee for the assessment year 2013-14 is delayed by 91 days, for which, the assessee has filed a petition for condonation of the delay in the form of Affidavit, to which; the ld....

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....operative credit society which extends credit facility to its members. Therefore, the Assessing Officer held that the interest income earned from the credit facilities provided to its members alone qualify for deduction under section 80(P)(2) of the Act. It was the contention of the ld. Counsel for the assessee that the interest income earned from the SBI Neyveli is incidental and attributable to the credit business activity of the society. While deleting the addition made towards interest income earned from another cooperative bank, the ld. CIT(A) has held that when the assessee society parked its funds temporarily in another co-operative society and earned interest which was ultimately used for providing credit to members the activities a....

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....s of sub-section 4 to section 80(P) of the Act attracts. On appeal, by following the decision of the Hon'ble Jurisdictional High Court decision in assessee's own case for earlier assessment years, the ld. CIT(A) deleted the addition. 9. We have heard the rival contentions. The ld. Counsel for the assessee has submitted that the issue whether the assessee is eligible to claim deduction under section 80(P)(2)(a)(i) of the Act is squarely covered by the decision of the Hon'ble Jurisdictional High Court in assessee's own case in Tax Case Appeal Nos. 786 to 789 of 2015 dated 10.08.2016 by following its own decision in assessee's own case for the assessment years 2007-08 to 2010-11 in TCA Nos. 735, 755 of 2014 and 460 of 2015 dated 05.07.2016. W....