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2021 (9) TMI 1557

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.....2 The Registry has noted a delay of 38 days in appeal for AY 2015-16, the condonation of which has been sought by the assessee on the strength of affidavit of Shri Mahesh Dhondiraj, Secretary of the assessee. In the affidavit, it has been stated that the hearing notices as well as the impugned order were accessed by employees in the office but were not brought to the notice of concerned officials. The Ld. CIT-DR, on the other hand, pointed out that the assessee did not appear during revisional proceedings. 1.3 After going through the contents of the affidavit, the bench formed an opinion that the delay deserve to the condoned and the assessee be provided another opportunity of hearing. Accordingly, the appeal is admitted and adjudicated a....

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....cs on shares held with the same entity. The Ld. AR submitted that since entire investment was in Co-operative Banks, both these components were eligible for deduction u/s 80P(2)(d). Reliance has been placed on various decisions of the Tribunal to support the same. The Ld. AR also submitted that the assessee claimed deduction u/s 80P(2)(a)(i) on entire net profit based on the decision of Hon'ble Bombay High Court in the case of The Quepem Urban Co-operative Credit Society Ltd. vs. Asst. CIT (2015) 377 ITR 272 and various other decisions as enumerated in the written submissions. The Ld. AR also submitted that Ld.AO, having taken possible view based on various judgments, his order cannot be said to be erroneous and prejudicial to the interests....