2024 (5) TMI 28

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....it facilities to its members. The Return of Income for the assessment year 2020-21 was filed on 11.02.2021 declaring total income of Rs. Nil after claiming deduction under u/s. 80P at Rs. 1,16,19,383/-. The return was processed u/s. 143(1) and the case was selected for scrutiny under CASS. On verification of the record, the AO noticed that the appellant earned interest & dividend income of Rs. 23,42,047/-. He was of the opinion that said income earned by the appellant is not income from the regular course of business and is to be assessed as income from other sources. Accordingly, the assessment was completed by the Assessing Officer u/s. 143(3) r.w.s.144B of the Act vide order dated 19.09.2022 disallowing assessee's entire claim of deducti....

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....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 scheduled 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 Hon'ble Delhi High Court in the case o....