2014 (11) TMI 1286

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....m Rastogi, C.A. ORDER A.K. Garodia, Member (A) 1. Both these appeals are filed by the Revenue in two different cases. I.T.A. No. 737/Lkw/2013 is in respect of Zila Ganna Utpadak Sahkari Samiti Ltd. for assessment year 2010-11, which is directed against the order of learned CIT(A), Bareilly dated 07/08/2013 and I.T.A. No. 738/Lkw/2013 is in respect of Sahkari Ganna Vikas Samiti Ltd. which ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....failed to prove with supporting documentary evidence that interest income was exclusively derived from deposits in the Saving Bank Account and not from Long-term Deposits made for long term investments out of surplus funds to earn interest income which does not qualify for deduction under section 80P(2)(d) of the I.T. Act, 1961 and therefore, the addition was rightly made by the Assessing Officer ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e Sale Society Limited 322-ITR-283 (SC) 2010 has held that the addition was made as interest from Post Office and Nationalized Bank (other than Cooperative Bank) and the assessee failed to prove with supporting documentary evidence that interest income was exclusively derived from deposits in the Saving Bank Account and not from Long-term Deposits made for long term investments out of surplus fund....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....n favour of the assessee by the Tribunal decision rendered in the case of Income Tax Officer v. Sahkari Ganna Vikas Samiti Ltd. in I.T.A. No. 817/Lkw/08 dated 28/11/2008. He submitted a copy of this Tribunal order. 5. We have considered the rival submissions. We find that in both these cases, the issue in dispute is regarding allowability of deduction u/s. 80P of the Act in respect of interest ....