2022 (6) TMI 78

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....ssessee's appeal for AY 2011-12 arises against the National Faceless Appeal Centre, Delhi's order dated 30-03-2022 passed in case No. ITBA/NFAC/S/250/2021- 22/1042118349(1) involving proceedings under Section 250 of the Income Tax Act, 1961 in short the Act. Heard both the parties. Case file perused. 2. The assessee pleads the following substantive grounds in the instant appeal : "1....

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....e learned I-T Authorities erred in law and on facts in disallowing deduction claimed u/s 80P(2)(a)(i) of the ITA, 1961 of Rs. 1,98,578/- on the analogy that appellant is dealing like a bank with its members. The learned I-T Authorities ought to have appreciated that in absence of any license from Reserve Bank of India, appellant cannot be treated as a 'bank'. 5. The learned I-T Au....

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....ts in not granting the enhanced deduction u/s 80P(2)(a)(i) of the ITA, 1961 on following disallowances as per CBDT Circular No. 37 of 2016: a) IDS debited to P&L A/c. : 28,773/- b) NPA provisions debited to P&L A/c.: Rs.17,44,572/- 7. The learned I-T Authorities erred in law and on facts by not allowing the proportionate deduction u/s 80P(2)(a)(i) of the ITA, 1961 to the....

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....e Cooperative Bank Ltd. Vs. CIT (2021) 123 taxmann.com 161 (SC) deciding the same against the department. 4. So far as the assessee's very deduction claim pertaining to interest income derived from deposits in cooperative banks is concerned case law State Bank of India Vs. CIT (2016) 389 ITR 578 (Guj.) and CIT Vs. Totagars Cooperative Sale Society (2017) 392 ITR 14 (Kar.) holds that such an inc....