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M/S Dhule Nandurbar District Police ... vs Income Tax Officer, Ward-1, Dhule, ... on 19 March, 2024
cites
Section 80P in The Income Tax Act, 1961 [Entire Act]
The Pr. Commissioner Of Income Tax, vs The Totagars Co-Operative Sale ... on 16 June, 2017
Accordingly, taking support from the
aforesaid judicial pronouncement of the Hon‟ble High
Court of jurisdiction, we respectfully follow the view taken
by the Hon'ble High Court of Karnataka in the case of Pr.
Commissioner of Income Tax and Anr. Vs. Totagars
Cooperative Sale Society (2017) 392 ITR 74 (Karn) and
that of the Hon'ble High Court of Gujarat in the case of
State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj),
wherein it was observed that the interest income earned
by a co-operative society on its investments held with a co-
operative bank would be eligible for claim of deduction
under Sec.80P(2)(d) of the Act.
Section 263 in The Income Tax Act, 1961 [Entire Act]
State Bank Of India vs Assistant Commissioner Of Income Tax on 4 November, 2022
Accordingly, taking support from the
aforesaid judicial pronouncement of the Hon‟ble High
Court of jurisdiction, we respectfully follow the view taken
by the Hon'ble High Court of Karnataka in the case of Pr.
Commissioner of Income Tax and Anr. Vs. Totagars
Cooperative Sale Society (2017) 392 ITR 74 (Karn) and
that of the Hon'ble High Court of Gujarat in the case of
State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj),
wherein it was observed that the interest income earned
by a co-operative society on its investments held with a co-
operative bank would be eligible for claim of deduction
under Sec.80P(2)(d) of the Act.
The Income Tax Act, 1961
K. Subramanian, Ito And Another vs Siemens India Ltd. And Another on 20 April, 1983
Backed by the
aforesaid conflicting judicial pronouncements, we may
herein observe, that as held by the Hon'ble High Court of
Bombay in the case of K. Subramanian and Anr. Vs.
Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom),
where there is a conflict between the decisions of non-
jurisdictional High Court‟s, then a view which is in favour
11
ITA.Nos.194 & 195/PUN./2024
of the assessee is to be preferred as against that taken
against him.