2026 (6) TMI 238

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... The captioned appeal at the instance of assessee pertaining to A.Y. 2020-21 is directed against the order dated 15.12.2025 framed by Addl/JCIT(A)-1, Delhi passed u/s. 250 of the Income Tax Act, 1961 (in short 'the Act') arising out of Intimation Order dated 25.11.2021 passed u/s. 143(1) of the Act. 2. The only issue for my consideration is disallowance u/s. 80P(2)(d) of the Act at Rs. 14,98,11....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... 143(1) of the Act disallowing deduction of Rs. 14,98,110/- claimed u/s. 80P(2)(d) of the Act. Assessee preferred appeal before ld.CIT(A) and ld.CIT(A) upheld the action of CPC disallowing the said deduction. Now the assessee is in appeal before this Tribunal. 6. I note that assessee in its ground-wise submissions made before ld.CIT(A) submitted that it has been earning interest from Cooperati....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ed interest income on investments kept with Cooperative Societies/Banks. The provisions of section 80P(2)(d) of the Act, provides for deduction towards any income by way of interest or dividend derived by a co-operative society from its investment with any other co-operative society. The term Cooperative Society has been defined u/s. 2(19) of the Act, which includes a co-operative society register....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....bunal on this very issue and the assessee's case is squarely covered in its favour. In the case of Thorapadi Urban Co-op Credit Society Ltd & Others vs ITO in W.P. Nos. 11172 and others, judgment dated 10.10.2023, the Hon'ble High Court of Madras following the decision of Division Bench of Hon'ble High Court of Madras in the case of CIT vs The Salem Agricultural Producers Co-operative Mark....