TaxTMI 
TaxTMI 
2026 (10) TMI 903
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....0P(2)(d), in respect of Interest on Fixed Deposit with Cooperative Bank. Appellants Prays to allow the same. 2. Without Prejudice to Ground No. 1, CIT(A) has erred in confirming Income at Rs. 43,70,080/- against NIL Income. Appellant Prays that Income will be NIL even after Interest on FD is treated as not eligible, as Business Income will result in Loss & Income from Interest on FD as Income from Other Sources will be adjusted against Loss, resulting Final Income at Rs. NIL. 3. Appellant denies liability of Interest u/s 234A & 234B. Appellant prays for cancellation of the same. 4. Appellant prays to add, alter, amend, take additional grounds, submit additional evidence, and/or withdraw the groun....
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....assessee. In this regard, we find that the Assessing Officer by placing reliance in the case of Totgar's Cooperative Sales Society Ltd. vs. ITO, 322 ITR 283 and also relying on the judgement of Hon'ble Karnataka High Court in the case of PCIT vs. The Totgar's Cooperative Sales Society, (2017) 83 taxmann.com 140 (Karnataka)and also in the light of section 80P(4) of the IT Act disallowed the deduction of Rs. 43,70,081/- u/s 80P(2)(d) claimed by the assessee with regard to interest income earned from its investments with other cooperative banks. In this regard, we find that the above issue is no more res integra in the light of various decisions passed by coordinate benches of this Tribunal including the case of Armed Forces Ex-Officers Multi ....
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....22 (Α.Υ. 2020-21) (v) Pune JilhaGramsevakvs. Income Tax Officer, Ward12(1), Pune dated 19 March, 2024 (AY 2018-19) 6.2 The Ld. AR further submitted that impugned issue has been decided by the Pune bench of the Tribunal in assessee's own case for A.Y.2013- 14 in ITA No. 787/PUN/2024 vide order dated 27.09.2024. 7. The Ld. DR, on the other hand, supported the order of the Ld. AO/CIT(A). 8. We heard the Ld. Representative of the parties and perused the material available on record as well as various judicial precedents cited by the Ld. AR in support of its claim of deduction u/s. 80P of the Act. The facts are not in dispute. During the relevant AY, the assessee has earned interest income from f....
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.... on its investments is eligible for deduction u/s 80P(2)(d) of the IT Act. It is worthwhile to mention here that though the co-operative banks pursuant to the insertion of subsection (4) to section 80P would no more entitle for claim of deduction u/s 80P of the IT Act but as a co-operative bank continues to be a co-operative societies registered under the Cooperative Societies Act in any State, the interest income derived by a cooperative society from its investments held with a cooperative bank would be entitled for claim of deduction u/s 80P(2)(d) of the IT Act. In this regard, we find support from the following decisions passed by the Co-ordinate Benches of this Tribunal :- (i) Kolhapur District Central Co-op. Bank KanistaSevaka....