2024 (10) TMI 653

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....f collecting deposits and lending money to its members. The Return of Income for the assessment year 2017-18 was filed on 29.10.2017 disclosing total income at Nil after claiming deduction of Rs. 54,88,523/- u/s. 80P(2)(a)(i) of the Income Tax Act, 1961 ('hereinafter also called 'the Act'). The case was selected for limited scrutiny under CASS. Statutory notice u/s. 143(2)/142(1) were issued to the appellant calling upon the appellant to file the requisite details. In response, the appellant filed the written submissions along with copy of audit report in Form No.3CA/3CD and bank statements. On verification of the details furnished by the appellant, the Assessing Officer noticed that the appellant received interest amount to the tune of Rs.....

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....e in the present appeal relates to the eligibility of the assessee for exemption u/s. 80P(2)(a)(i) of the Act in respect of interest income earned from Nationalised Banks. 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 Nationalised 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 Ind....