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Mala Block Town Co-operative Bank Limited v. The Income Tax Officer

Case No: ITA No.554/Coch/2023 & 827/Coch/2023
Court: Income Tax Appellate Tribunal, Cochin Bench
Date: 9/25/2024

Parties Involved

appellantMala Block Town Co-operative Bank Limited
respondentThe Income Tax Officer

Facts Summary

The assessee, Mala Block Town Co-operative Bank Limited, filed twin appeals ITA No.554/Coch/2023 & 827/Coch/2023 for the assessment year 2020-2021 against the disallowance of interest income from Treasury amounting to Rs.4,16,125 under Section 80P(2)(d) of the Income-tax Act, 1961. The Assessing Officer relied on the decision of the Hon'ble High Court of Kerala in Peroorkada Service Cooperative Bank (ITA Nos.142 & 323/2019 dated 01.11.2021) which held that interest income earned from Treasury is not entitled for deduction under Section 80P(2)(d). The assessee argued based on CBDT Circular No. 133 of 2007 and an Apex Court decision in Mavilayi Service Co-operative Bank Limited. However, the decision of the Assessing Officer was upheld as it was based on the jurisdictional Kerala High Court decision.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Disallowance of interest income from Treasury amounting to Rs.4,16,125 under Section 80P(2)(d) of the Income-tax Act, 1961

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

4 precedents cited in this judgement.

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Mala Block Town Co-operative Bank Limited v. The Income Tax Officer | ITA No.554/Coch/2023 & 827/Coch/2023 |… | Opakhya