2025 (4) TMI 1267

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.... PER RAJESH KUMAR, AM: This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 08.04.2024 for the AY 2020-21. 02. The issue raised by the assessee in grounds no.1 is against the order of ld. CIT (A) confirming the action of the ld. AO wherein the ld. AO treated the interest income of Rs. 2....

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....ating the same as profit from business of banking/ providing credit facilities to its members. The ld. AO denied the said deduction u/s 80P(2)(a) of the Act on the ground that the interest income was not attributable to the business activity of the assessee in providing banking/ credit facilities to its members in the assessment framed u/s 143(3), read with section 144B of the Act dated 19th Septe....

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....attributable to the business activity of the assessee by providing banking and credit facilities to its members. We note that the ld. AO relied on the decision of Hon'ble Apex Cort in the case of Saptagiri Pattina Souharda Sahakari Sangha Niyamitha vs. Income-tax Officer [2024] 162 taxmann.com 855 (Bangalore - Trib.)/[2024] 207 ITD 41 (Bangalore - Trib.)[22-05-2024], while rejecting the deduct....

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....e deposits of banks held to be eligible for deduction u/s 80P(2)(a) of the Act. The Hon'ble Calcutta High Court held while passing the said decision relied on the decision of Hon'ble Karnataka High Court in case of Guttigedarara Credit Co-operative Society Ltd. vs. Income-tax Officer, Ward 2(2), Mysore [2015] 60 taxmann.com 215 (Karnataka)/[2015] 234 Taxman 476 (Karnataka)/[2015] 377 ITR 4....