2024 (4) TMI 647

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....ear 2018-19 was filed on 22.08.2015 declaring total income of Rs. Nil after claiming exemption u/s 80P(d)(a)(i)/80P(2)(d) of the Income Tax Act, 1961 ('the Act') of Rs. 26,73,789/- and offered the income of Rs. 30,350/- to tax. The case was selected for Limited Scrutiny to examine the (i) Investments/Advances/Loans and (ii) Deduction from total income under Chapter VI-A. The assessment was completed by the Assessing Officer vide order dated 02.03.2021 passed u/s 143(3) r.w.s. 143(3A) & 143 (3B) of the Act determining total income at Rs. 9,70,022/-. While doing so, the Assessing Officer had brought to tax the interest earned on FDs with other co-operative banks holding that the said interest does not qualify for deduction u/s 80P(2)(a)(i) of....

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....ed on the decision of the Hon'ble Bombay High Court in the case of PCIT vs. Quepem Urban Co-operative Credit Society Ltd., 438 ITR 631 (Bom.). 8. As regards, the issue as to the allowability of exemption under the provisions of section 80P(2)(a)(i) in respect of interest income earned by a cooperative society from the schedule banks, there is a cleavage of judicial opinion among several High Courts on the issue of eligibility of this kind of income for exemption u/s. 80P(2)(a)(i) of the Act. The Hon'ble Punjab & Haryana High Court in the case of CIT vs. Punjab State Cooperative Federation of Housing Building Societies Ltd. 11 taxmann.com 448, the Hon'ble Gujarat High Court in the case of State Bank of India Vs. CIT 389 ITR 578 (Guj.), the ....