Section 80P deduction for deposit income and strict reassessment limitation determine the treatment of consequential penalty proceedings.

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....Section 80P deduction for interest and dividend income from compulsory, fixed and savings-bank deposits is discussed as available where the deposits are attributable to a credit co-operative society's business of providing credit facilities to members. The note distinguishes investment income treated as business income from the contrary context of investments with co-operative banks. It also addresses reassessment beyond three years, stating that the extended limitation period requires strict satisfaction of statutory conditions and cannot rest on cash-deposit allegations that do not survive; a deduction disallowance alone must meet the applicable threshold. Consequential under-reporting penalty proceedings may require fresh consideration where the underlying assessment is restored.....