2023 (7) TMI 860

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....amounting to Rs. 2,20,808/-. 2. Assessee is in the business of providing credit facilities to its members and is covered under section 80P and has rightly claimed deduction under section 80P(2)(a)(i) of the I.T. Act, 1961. 3. The assessee pray that deduction under section 80P(2)(a)(i) of the Act is eligible, hence addition of Rs. 2,20,808/- made by Ld. AO is unwarranted and bad in law and therefore be deleted. 4. Without prejudice to above, Assessee prays that Pro Rata Expenses for earning interest income be allowed. The Assessee prays that total expenditure incurred for the year stood at Rs. 16,09,394/-, total income for the year stood at Rs. 17,60,194/- and interest income on investment stood at Rs. 2,20,808/-. Hence pro rata expens....

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....ssee has correctly claimed deduction under Section 80P(2)(a)(i) of the Act which provides that whole of the amount of profit and gains of business attributable to activities specified under Section 80P(2)(a)(i) to (vii) is deductible under Section 80P(1). The assessee is a primary cooperative society registered under Gujarat Co. Op. Society Act, 1961 and is eligible to get deduction under Section 80P(2)(a)(i) of the Act. The Ld. A.R. further submitted that the interest income on surplus fund invested cannot be taxed under Section 56 as it did not carry out any activity except in providing credit facilities to its members and that the funds were of operational funds. The only fund available with the assessee was deposits from its members and....