2025 (8) TMI 667

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....fter referred to as "Act"] for Assessment Years [A.Y.] 2016-17 & 2017-18. 2. The assessee has raised following grounds of appeal: ITA No. 5894/Mum/2024 "In the facts and circumstances of the case and in law, the Learned National Faceless Appeal Centre (NFAC) CIT (Appeals) has erred in confirming disallowance of deduction claimed of Rs. 3,04,21,874/- under section 80P(2)(d) of the Act." ITA No. 5893/Mum/2024 1. In the facts and circumstances of the case and in law, the Learned National Faceless Appeal Centre (NFAC) CIT (Appeals) has erred in confirming disallowance of deduction claimed of Rs. 2,94,40,756/- under section 80P(2)(d) of the Act. 3. In both the appeals, sole issue involved is regarding cl....

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....0/Mum/2019 & others (assessee's own case) 7. On the other hand, Ld. DR vehemently argued that the issue is covered against the assessee by the Hon'ble Karnataka High Court's decision in the case of PCIT v/s Totalgars Cooperative Sales Society in 395 ITR 611 and argued that the interest earned from the co-operative banks does not fall under the purview of section 80P(2)(d) of the Act. 8. We have considered the rival submissions and perused the material placed before us as well as judicial pronouncements on the issue. It is seen that the issue is covered in favour of the assessee in various decisions of the co-ordinate benches as well as subsequent decisions of the Hon'ble Karnataka High Court and Gujarat High Court. 9. In assessee's....