2025 (6) TMI 563

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.... against equity and principles of natural justice. 2. The learned assessing officer treated the interest received from Thrissur District Co-operative Bank Ltd and Kodungallur Town Co-operative Bank Ltd.as income from other sources and taxed u/s 56 of the Income Tax Act on the reason that interest income earned by the appellant on the deposit with co-operative banks are assessable under the head 'income from other sources". The learned assessing officer failed to appreciate that Thrissur District Co- operative Bank Ltd and Kodungallur Town Co-operative Bank Ltd are co-operative societies registered under the Kerala Co-operative Societies Act and the interest from district/state co operative banks are eligible for deduction u/s 80P(2)(d....

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.... claimed u/s. 80P(2)(a)(i) of the Act on the ground that the interest income earned from the co-operative banks are not the profits and gains of the business carried on by the assessee. 3. Challenging the said order, the assessee filed an appeal before the Ld.CIT(A) and contended that the interest income earned from the cooperative banks are eligible for deduction. The Ld.CIT(A) rejected the said contention and held that the interest income earned from the scheduled banks and co-operative banks are also incomes received from non-member category and therefore the same could not be considered for deduction u/s. 80P(2)(a) to 80P(2)(d) of the Act but liable to be assessed u/s. 56 of the Act. The Ld.CIT(A) had observed that the interest income ....