2023 (2) TMI 134

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....EMBER For the Assessee : None For the Revenue : Shri Keyur Patel, CIT-DR and Shri Ramnath P. Murkunde ORDER PER R.S.SYAL, VP: These two appeals by the Revenue pertaining to different assessees relate to the assessment year 2018-19. Since a common issue is raised in these two appeals, we are, therefore, proceeding to dispose them off by this consolidated order for the sake of conveni....

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....ore. Aggrieved thereby, the Revenue has come up in appeal before the Tribunal challenging the order passed by the ld. CIT(A). ITA No.628/PUN/2022 : 3. In this appeal, the Revenue is aggrieved by the granting of deduction u/s.80P in respect of interest and dividend income on the funds invested in scheduled banks/financial institutions. The facts of this case are that the assessee, a co-operat....

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....rst appeal. Insofar as the allowability of deduction u/s.8P(2)(a)(i) is concerned, we find that the Pune Benches of the Tribunal in Sureshdada Jain Nagari Sahakari Patsanstha Maryadit Vs. The Pr.CIT (ITA No.713/PUN/2016) has decided the question of availability of deduction u/s 80P on interest income by noticing that the Pune Bench in an earlier case of Shri Laxmi Narayan Nagari Sahakari Pat Sanst....

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....Sanstha Maryadit (supra) preferred to go with the view in favour of the assessee by the Hon'ble Karnataka High Court in the case of Tumkur Merchants Souharda Credit Cooperative Ltd. (supra). The position continues to remain the same before this Tribunal also. 6. Coming to the eligibility of deduction u/s.80P(2)(d) and after considering the language of the section, it is observed that though co-....