2025 (11) TMI 820

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....Respondent: None. P.C.:- 1. Heard Mr. Sharma for the Appellant. 2. Mr. Sharma proposes the following substantial questions of law in support of this Appeal:- A. Whether on the facts and circumstances of the case and in law, the Tribunal was justified in dismissing the appeal of the revenue by not appreciating the fact that deduction of interest u/s. 80P(2)(d) from deposit of surp....

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.... be allowed only where a cooperative society parks its surplus funds with another cooperative society. He submits that in the present case, the Assessee cooperative society chose to park its surplus funds with a "cooperative bank" and not a cooperative society. He submitted that the ITAT has not recorded any finding that the cooperative bank in question was also a cooperative society registered un....

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....case of Principal Commissioner of Income Tax & Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) which have taken the similar view. 6. Recently, the Gujarat High Court, in the case of Principal Commissioner of Income Tax Vs. Shree Madhi Vighag Khand Udyog Sahakari Mandli Ltd. [2025] 171 taxmann.com 22 (Gujarat) has reiterated the same view holding that a deduction under Sectio....