2024 (1) TMI 851

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.... CA For the Revenue : Smt. J.M. Jamuna Devi, Sr. D.R. ORDER PER SANJAY ARORA, AM This is an Appeal by the Assessee agitating the Order dated 23.03.2023 by the Commissioner of Income Tax (Appeals), Income Tax Department [CIT(A)], dismissing the assessee's appeal contesting it's assessment under section 143(3) of the Income Tax Act, 1961 (hereinafter "the Act") for Assessment Year (AY) 2....

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....erative Bank Ltd. [2022] 442 ITR 141 (Ker). 4. We have heard the parties, and perused the material on record. The Revenue authorities have, we find, denied the assessee's claim in view of the decision in Totgar's Co-operative Sales Society Ltd. vs. ITO [2010] 322 ITR 283 (SC) which, as argued by Shri Ramdas, the learned counsel for the assessee, stands considered in Peroorkkada Service Co-op....

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....e same, where otherwise eligible, stands to be deducted u/s.80P(2)(d) of the Act. Continuing further, whether assessable as business income or otherwise, where the same forms part of the gross total income, the same, on satisfaction of the condition/s therefor, would qualify for deduction under the relevant clause of section 80P of the Act. The matter has been explained by the Cochin Bench per it'....