2024 (4) TMI 1112

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....RAMA RAO, AM: This is an appeal filed by the assessee directed against the order of the National Faceless Appeal Centre, Delhi ['NFAC'] dated 22.02.2024 for the assessment year 2018-19. 2. Briefly, the facts of the case are that the appellant is a Souhard Cooperative registered under the Maharashtra Cooperative Society Act, 1960, engaged in providing credit facilities to its members. The Ret....

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....confirmed the action of the Assessing Officer. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. It is submitted before me that the issue is decided in favour of the assessee by placing reliance on the several decisions of the Tribunal as well as the decision of the Co-ordinate Bench of this Tribunal in the case of Sai Prerana Gramin Bigarsheti Sah....

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....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 Hon'ble Delhi High Court in the case of M....

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....Co-operative Rural Bank Ltd. v CIT [(2017) 396 ITR 371 took a view that such interest income is attributable to the activities of the society and, therefore, eligible for exemption u/s 80P(2)(a)(i) of the Act. Similar view has been taken by the Hon'ble Calcutta High Court in the case of PCIT vs. Gunja Samabay Krishi Unnayan Samity Ltd., 147 taxmann.com 518 (Calcutta) and the Hon'ble Madras High Co....