2025 (2) TMI 1892

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....iswaran, C.A For the Respondent : Shri P.K. Senthil Kumar, Addl. CIT ORDER PER JAGADISH, A.M : Aforesaid appeal filed by the assessee for Assessment Year (AY) 2018-19 arises out of the order of Learned Commissioner of Income Tax, National Faceless Appeal Centre (NFAC), Delhi [hereinafter "CIT(A)"] dated 20.07.2024 in the matter of assessment framed by the Assessing Officer [AO] u/s. 14....

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....1 Dividend from Investment in shares 1,42,386 Total 26,13,527 3. The A.O has disallowed the claim u/s. 80P(2)(d) of the Act holding that investment in co-operative banks is not eligible for deduction u/s. 80P(2)(d) of the Act. The assessee has also claimed deduction of Rs. 1 Cr. u/s. 80P(2)(c) of the Act. The A.O has restricted the claim to Rs. 50 Lakhs u/s. 80P(2)(c)(ii) of the Act....

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....n Co-op. Credit Society Ltd., vs. ITO, supra, relying on the decision of Division Bench in the case of CIT vs. The Salem Agricultural Producers Co-operative Marketing Society, supra, has held that co-operative bank falls within the purview of Co-operative Society hence, interest and dividend earned are allowed for the purpose of deduction u/s. 80P(2)(d) of the Act. The Ld AR on the issue of deduct....

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....decision of the Hon'ble Madras High Court in the case of CIT vs. The Salem Agricultural Producers Co-operative Marketing Society, supra, wherein it has been held that income earned from interest and dividends derived from co-operative bank, which is also a Co-operative Society, is entitled for deduction u/s. 80P(2)(d) of the Act, provided the bank is registered under the Tamil Nadu Societies Act. ....