2025 (3) TMI 1570

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....ORAD, AM: This appeal filed at the instance of assessee is directed against the order of Ld. CIT(A)/NFAC dated 30.03.2024 which is arising out of the assessment order u/s 143(3) r.ws. 144B of the Act for Assessment Year 2020-21 framed on 22.09.2022 by the ITO, NFAC. 2. The sole grievance of the assessee that Ld. CIT(A)/NFAC erred in confirming the disallowance u/s 80P(2)(a)(i)/80P(2)(d) of t....

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....hat the assessee has invested surplus funds with cooperative banks and other banks which are not eligible for deduction and such interest income from such investments are not allowable u/s 80P(2)(d) of the Act. Ld. Assessing Officer taking into consideration the fact that the assessee has admitted nominal/associate members who do not have voting rights, the principle of mutuality is violated and t....

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....hand, Ld. DR supported the orders of the lower authorities. 7. We have heard rival contentions and perused the records placed before us. We observe that the assessee which is a co-operative society has declared income of Rs.3,92,570/- after claiming deduction u/s 80P at Rs. 1,33,50,608/-. We also observe that during the year the assessee society has earned interest income of Rs.18,96,95,893/- a....