2025 (2) TMI 1951

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....nce common issues have been raised in both these appeals, these have been heard together and are being disposed for by this consolidated order for the sake of convenience. 3. Assessee has raised following grounds of appeal for A.Y. 2018-2019 :- "1. On the facts and in the circumstances of the case and in law, the learned Assessing Officer erred in rejecting deduction u/s 80P(2)(a)(i) for a sum of Rs 70.71,431/- being part of the book profit of appellant society without appreciating the fact that earning of interest is an integral part of society's business and appellant prays for allowing such deduction. 2. On the facts and in the circumstances of the case and in law, the learned Assessing Officer erred in treating ....

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....interest is an integral part of society's business and appellant prays for allowing such deduction 2. On the facts and in the circumstances of the case and in law, the learned Assessing Officer erred in treating the interest received from investment a sum of Rs. 52,14,519/-, as income from other sources by rejecting appellants contention that said interest income is integral part of business activity and your appellant prays for cancellation of Assessing officer's action. 3. Without prejudice to above ground on the facts and in the circumstances of the case and in law, the Learned Assessing Officer in not allowing the deduction under section 80P(2)(d) on interest income received from other co-operative society. You....

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....e heard the ld. Departmental Representative and perused the record placed before us. The solitary issue in the instant appeal is whether the assessee is entitled for deduction u/s 80(P)(2)(d) of the Act on the interest earned on deposits made with other Co-operative Banks. We notice that the assessee which is a co-operative society has been subjected to the scrutiny proceedings and in the order framed u/s 143 r.w.s 147 of the Act dated 23.09.2022 various additions were made by the Assessing Officer (AO). The same were challenged by the assessee and substantial relief was granted by CIT(A). However, for the addition of of Rs. 70,71,431/- and Rs. 11,54,341/- for A.Y. 2018-19 and A.Y. 2020-21 respectively, ld. CIT(A) affirmed the action of the....