2024 (9) TMI 342

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....case are that the appellant is a Co-operative Credit Society registered under Multi State Co.op Societies Act, 2002. It is engaged in the business of providing credit facilities to its members, accepting deposits and giving loans to the members as per the cooperative laws. The appellant society filed the Return of Income for the assessment year 2014-15 on 25.09.2014 declaring total income at Nil. During the year under consideration, the assessee received interest income of Rs.3,39,44,265/- from the deposits made with commercial banks, cooperative banks and cooperative societies. Against the said return of income, the assessment was completed by the Assessing Officer (AO) vide order dated 23.11.2016 passed u/s 143(3) of the Act at a total in....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rival submissions and perused the material on record. Admittedly, the appellant is a Cooperative society formed under the provisions of Maharashtra Cooperative Societies Act,1960 with the objective of accepting deposits and lending money to its members. The money which is not immediately required for the purpose of lending to the members is deposited with Bank of Baroda in the form of Fixed Deposit. The question is whether the interest so earned qualifies for exemption u/s. 80P(2)(a)(i) of the Act. The AO as well as the CIT(A) were of the opinion that the interest earned from third parties or non- members does not quality for exemption u/s.80P. It is an admitted position that the interest so earned should be taxed as 'income from other sour....