2023 (4) TMI 854

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....der Section 80P of the Income Tax Act. It is submitted that on facts and circumstances of the case the appellant has rightly claimed the interest received from SBI and Dena bank savings account under Section 80P of the Income Tax Act. It is submitted that the same be allowed now. 2. Without prejudice to the above it is submitted that if the aforesaid interest received from nationalized bank are not allowable under Section 80P of the Income Tax Act, then proportionate expenditure to earn such interest income must be allowed as deduction while making disallowance. It is submitted that the same be allowed now. 3. The Ld. CIT(A) has erred in confirming disallowance of an amount of Rs.11,23,088/- under Section 80P(2)(d) of the income Tax Act....

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....e. Mehsana Urban Co-operative Bank and Mehsana District Central Co-operative Bank Limited savings and Fixed Deposit and as the assessee claimed deduction under Section 80P(2)(d) of the Act. 4. Being aggrieved by the Assessment Order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee. 5. The Ld. AR in respect of ground no.1 submitted that the same is decided against the assessee as the interest was received from State Bank of India and Dena Bank savings accounts which is not permissible as per the decision of the Hon'ble Gujarat High Court in the case of State Bank of India vs. CIT. 6. The Ld. DR relied upon the Assessment Order and the order of the CIT(A). 7. Heard both the parties and perused ....