2025 (3) TMI 2036

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....ppeal:- 1. The learned AO and CIT(A) grossly erred in denying the deduction under section 80P(2)(d) on interest received on investment with cooperative societies or cooperative Banks to the assessee. The deduction u/s 80P(2)(d) be allowed to the assessee. 2. Without prejudice to the above, the assessee is eligible for deduction u/s 80P(2)(a)(i) of the Act in respect of interest income and same should be allowed. 3. On the facts and circumstance of the case and in law the levy of interest U/s 234A, 2348, 234C is not justified. 4. The appellant craves leave to add/amend or alter any of the above grounds of Appeal. 3. Sole grievance of the assessee is that Ld. CIT(A) erred in not allowing deduction u/s 80....

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....ed from banks is concerned, I find that the Pune Tribunal in Suresh dada Jain Nagari Sahakari Patsanstha Maryadit Vs. The Pr.CIT (ITA No.713/PUN/2016) has decided the question of availability of deduction u/s 80P on interest income by noticing that the Bench in an earlier case of Shri Laxmi Narayan Nagari Sahakari Pat Sanstha Maryadit Vs. ITO (ITA No.604/PN/2014) has allowed similar deduction. In the said case, the Tribunal discussed the contrary views expressed by the Hon'ble Karnataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (2015) 230 Taxman 309 (Kar.) allowing deduction u/s. 80P on interest income and that of the Hon'ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd. Vs. CIT (20....