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2017 (10) TMI 1524
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....t from 01.04.2007 introducing subsection (4) which laid down specifically that the provisions of section 80P will not apply to any cooperative bank and accordingly deduction u/s 80P was no more available to any regional rural banks from Assessment Year 2007-08. 2. That the ld CIT(A) has erred in deleting the addition of Rs. 8607600/- in view of the OM Dated 25.08.2006 addressed to RBI clarifying that regional Rural Banks would not be eligible for deduction u/s 80P of IT Act from Assessment Year 2007-08. 3. The ld CIT(A) erred in deleting the addition of Rs. 8607600/- in view of the circular NO. 6/2010 dated 20.09.2010 which clarified that circular BNO. 319 dated 11.01.1982 deeming any Regional Rural Bank to be cooperative ....
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....eerut who per order dated 20/09/2013 allowed the claim of the assessee of exemption of dividend from cooperative societies holding that provisions of section 80 P (2) (d) covers the above exemption. 5. Revenue aggrieved with the order of the Ld. CIT (A) has preferred an appeal before us. The Ld. departmental representative submitted that it has been clarified wide circular dated 25/08/2006, wherein it has been stated that regional rural banks would not be eligible for deduction under section 80 P of the income tax act from assessment year 2007 - 08. He therefore submitted that for assessment year 2007 - 08, no exemption under section 80 P of the act is allowable to the regional rural banks holding them as cooperative banks. 6. The Ld.....
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....igible for deduction under section 80P, CBDT issued a beneficial Circular No. 319 dated 11-1-1982, which stated that for the purpose of section 80P, a Regional Rural Bank shall be deemed to be a cooperative society. 3. Section 80P was amended by the Finance Act, 2006, with effect from 1-42007 introducing sub-section (4), which laid down specifically that the provisions of section 80P will not apply to any cooperative bank other than a Primary Agricultural Credit Society or a Primary Cooperative Agricultural and Rural Development Bank. Accordingly, deduction under section 80P was no more available to any Regional Rural Bank from assessment year 2007-08 onwards. An OM dated 25-8-2006 addressed to RBI was issued by the Board ....