TaxTMI 
TaxTMI 
2023 (11) TMI 440
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....2. In its appeal, the assessee has raised the following grounds:- "1. On facts, in circumstances of the case and in law, learned CIT-A ought to have deleted interest u/s 234A, 234B, 234C of Rs. Total 58,739/-. 2. The appellant craves leave to add, alter, modify or delete any of the above Grounds of Appeal. 3. On facts, in circumstances of the case and in law, learned CIT-A ought to have held that adjustment made to total income by Centralised Processing Centre, Bangalore was outside the scope of provisions of section 143(1) of the Income Tax Act, 1961. 4. On facts, in circumstances of the case and in law, learned CIT-A ought to have allowed the claim of deduction u/s 80(P)(2)(d) of the appellant society in respect of interest income....
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....e Bank Ltd and Maharashtra State Co-operative Bank Ltd. 6. Before proceeding further, it is relevant to note the provisions of section 80P of the Act under which the assessee has claimed the deduction in the present case. As per the provisions of section 80P(1) of the Act, the income referred to in sub-section (2) to section 80P shall be allowed as a deduction to an assessee being a Co-operative Society. Further, section 80P(2)(d) of the Act, reads as under: "80P. Deduction in respect of income of co-operative societies. (1) ...... (2) The sums referred to in sub-section (1) shall be the following, namely:- (a) ..... (b) ..... (c) ..... (d) in respect of any income by way of interest or dividends derived by the co-operative s....
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....hich was claimed as a deduction under section 80P(2)(d) of the Act. The deduction under section 80P(2)(d) of the Act was denied on the basis that the Saraswat Co-operative Bank Ltd and Maharashtra State Co-operative Bank Ltd are multi-state scheduled banks and therefore interest derived will not qualify for deduction under section 80P(2)(d) of the Act. However, from the perusal of section 80P(2)(d) of the Act, it is sufficiently evident that there is no restriction on claiming deduction under the said section in respect of interest income earned from the Co-operative society operating in multiple states. Further, section 80P(4) of the Act is of relevance only in a case where the taxpayer, who is a Co-operative Bank, claims a deduction under....