2024 (7) TMI 222

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....Akhilesh Srivastava ORDER PER INTURI RAMA RAO, AM: These are two appeals filed by the assessee directed against the separate orders of National Faceless Appeal Centre (NFAC), Delhi dated 11.03.2024 for the assessment years 2018-19 & 2020-21. 2. Since the identical facts and common issues are involved in the above captioned appeals of the assessee, we proceed to dispose of the same by t....

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....icer') vide order dated 20.04.2021 passed u/s 143(3) r.w.s.144B of the Act assessing total income of Rs. 1,53,24,770/-. While doing so, the Assessing Officer had denied the exemption u/s. 80P(2)(d) in respect of interest income earned out of the deposits made with Cooperative banks as well as Nationalised banks. 4. Being aggrieved, an appeal was filed before the CIT(A)/NFAC who vide impugned or....

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....nks, there is a cleavage of judicial opinion amongst 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 ....

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.... and Hon'ble Andhra Pradesh High Court in the case of Vaveru 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., ....