operative Sale Society, Sirsi, is entitled to
100% deduction under Section 80P(2)(d) of
the Income Tax Act, 1961 (for short ... deductible from the Gross Total
Income under Section 80P(2)(a)(i) of the
Act, is not applicable to the present
Assessment Years
ground that the denial of the benefit of deductions under
Section 80P(2)(a) of the Act to the petitioners, by the
Assessing Officer ... denials, by the Assessing Officers, of the benefit of
deduction under Section 80P(2)(a) to the petitioners is correct
or not.
5. Though
Group-II
12.Next is about allowing deduction u/s.80P of the Act.During the assessment proceedings,
the AO held that the society ... violated the principles of mutuality,that the provisions of
section 80P were not applicable to a Co-op.Housing Society,that the assessee had made
been approved by Ld. CIT(A)
while granting deduction under S. 80P(2)(a)(i) of the Act, then the
principle of mutuality makes ... justified in not granting deduction u/s 80P(2)(a)(i) in respect of
the following additions made and confirmed by him:
a. FDs standing
assessee. Ld.
Assessing Officer while examining the claim of deduction u/s
80P(2)(a)(i) of the Act framed a view that assessee ... society and therefore, is out of
the ambit of provisions of section 80P(2)(a)(i) of the Act and falls
under the provisions
when the business income of assessee
bank was totally exempt u/s 80P of I.T. Act, 1961 amounts to cessation
of those liabilities ... business. The income
of assessee co-operative Bank was exempt u/s 80P(2) of I.T. Act, 61 in
all the earlier year
erred in confirming the disallowance of the deduction
under section 80P(2)(d) of the Act, in respect of interest income
aggregating ... deposits placed with Co-operative Banks, relying on the provisions
of section 80P(4) of the Act."
3. The issue raised by the assessee
confirming the disallowance of deduction claimed u/s 80P of the
I.T. Act of Rs.2,08,70,799.
4. Brief facts ... assessee. He therefore, disallowed the claim of deduction u/s 80P
of the Act and brought the entire amount to tax. Aggrieved, the
assessee preferred
allowing the deduction
claimed by the assessee u/s. 80P of the Act, there was an additional ground of
Cross Objection ... income from other sources, thereby denying the claim of deduction
under section 80P(2)(a) (i) and section 80P
assigned to them in the Explanation to sub-section (4) of section 80P
