2025 (12) TMI 47

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ssment order dated 31/3/2021 passed under section 143(3) of The Income - Tax Act, 1961 (the Act) passed by the National e-Assessment Centre, Delhi (the learned AO) whereby the denial of deduction under section 80 P of the act of Rs. 2,146,478/- was confirmed. 2. The appeal is preferred substantively on ground number 2 and 3 of the appeal wherein it challenged the confirmation of the order of the assessing officer denying deduction claimed of Rs. 2,146,478/- under section 80P(2)(a)(i)/(d) being interest on from cooperative banks and further as per ground number 3 it was not considered that the net interest offered to tax is only Rs. 646,052. 3. The assessee filed its return of income for assessment year 2018 - 19 and 30/9/2018 at Rs. 6....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..../- to the assessee and rejected the alternative claim of the assessee that as interest is received from a Central cooperative bank, it is also entitled to deduction under the provisions of section 80P(2)(d) of the act. Consequently, the assessment order was passed on 31/3/2021. 6. The assessee challenged in appeal before the ld. CIT (A) who dismissed the claim of the assessee following the decision of the honourable Karnataka High Court in case of 83 taxmann.com 140. Therefore, assessee is in appeal before us. 7. We have heard the contentions of the learned authorised representative as well as the standing counsel for the Department. The only issue involved in this appeal is whether the assessee is entitled to deduction under section ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....t [supra] has extracted certain definitions as under: - What is the Definition of cooperative Societies under the Income -tax Act, 1961? "2. In this Act, unless the context otherwise requires, -- (19) "co-operative society" means a co-operative society registered under the Co- operative Societies Act, 1912 (2 of 1912), or under any law for the time being in force in any State for the registration of co-operative societies." What quantum and characteristics of Income is eligible for deduction u/s 80P(2)(d) of the Act (d) in respect of any income by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society, the whole of such income. The definit....