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M/s. Mangala Credit Co-operative Society Ltd. Vs. The Income Tax Officer

Case No: ITA No. 1439/Bang/2024
Court: Income Tax Appellate Tribunal, SMC-‘B’ Bench, Bangalore
Date: 10 Oct 2024

Parties Involved

appellantM/s. Mangala Credit Co-operative Society Ltd.
respondentThe Income Tax Officer

Facts Summary

The assessee, a co-operative society registered under the provisions of the Karnataka Co-operative Societies Act, returned an income of Rs. 64,480/- for the assessment year 2018-19 and claimed the interest income received as a deduction under section 80P(2)(a)(i) of the act. The assessing officer disallowed the deduction claimed by the assessee. The assessee challenged this order before the CIT(A) and raised six grounds, contending that the interest income is eligible for deduction under section 80P(2)(a)(i) of the act. The CIT(A) dismissed ground no. 1 and allowed the other grounds. The assessee then appealed to the Tribunal against the order of the CIT(A).…

Decision in favour of

Assessee

Legal Issues

  • 1. Was the CIT(A) justified in sustaining the addition for Interest on Investment income of Rs. 13,85,295/- made by the Respondent?
  • 2. Does the interest on investments from Co-operative Banks of Rs. 9,78,882/- qualify for deduction under section 8P(2)(d) of the Act?
  • 3. Should the deduction of Rs. 3,33,555/- in respect of S.B. interest of Rs. 3,33,555/- derived from Co-op. Society under section 80P(2)(d) of the Act be allowed?
  • 4. Should the deduction under section 57(iii) of the Act for cost of funds used for investment in Term Deposits be allowed?
  • 5. Did the authorities below pass the impugned Orders contrary to established principles laid down by the Hon'ble Supreme Court and jurisdictional High Court?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

4 precedents cited in this judgement.

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