2025 (2) TMI 1212

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....stered under the Maharashtra State Co-operative Society Act, 1960. It is engaged in the business of accepting deposits from members and providing credit facilities to its members. For AY 2018-19, the assessee filed its return on 29.09.2018 declaring total income of Rs.NIL after claiming deduction of Rs.29,05,409/- under the provisions of sections 80P(2) of the Income Tax Act, 1961 (the "Act"). During the assessment proceedings, the Ld. Assessing Officer ("AO") found that the assessee has earned interest income from investments in Co-operative Banks amounting to Rs. 82,64,123/-. The Ld. AO disallowed the deduction claimed by the assessee u/s. 80P(2)(a)(i)/ 80P(2)(d) of the Act observing that the interest income earned by the assessee from in....

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....6-06-2017. In that judgement Hon'ble court held that deduction u/s 80P(2)(d) is not allowed on interest earned from deposit with other co-op society. Thus, respectfully following above judgement of Hon'ble Supreme Court & Karnataka High Court the deduction u/s 80P is not allowed on interest earned from deposit with nationalized bank & Co-operative banks." 3.1. The Ld. CIT(A) further observed that there is a mistake in computation of income and the correct amount of deduction claimed u/s. 80P should be Rs. 29,44,398/- and not Rs.29,05,409/- claimed in the return of income filed by the assessee. 4. Dissatisfied, the assessee is in appeal before the Tribunal raising the following solitary ground of appeal: "1. On the fac....

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....heti Sahakari Pat Sanstha Ltd. (ITA No.853/PUN/2024 dtd. 31.07.2024)" 5.2. The Ld. AR also submitted that the impugned issue has been decided in favour of the assessee by the Co-ordinate Bench of the Tribunal in assessee's own case for the previous AY 2017- 18, a copy of which was placed on record before us. 6. The Ld. DR supported the order of the Ld. CIT(A)/ AO. 7. We have heard the Ld. representatives of the parties and the perused the material available the on record as well as various judicial precedents cited by the Ld. AR. The facts are not in dispute. During the relevant AY, the assessee has earned interest income from investments in four co-operative banks, namely: (i) The Sarasvat Co-operative Bank Limited, (ii) Pavan....