STATE BANK OF INDIA OFFICERS CO-OPERATIVE CREDIT SOCIETY LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-5(3), HYDERABAD

Coming to the assessee's sole substantive grievance challenging correctness of both the lower authorities’ action declining 80P(2)(a)(i) deduction of Rs.75,02,196; there is hardly any dispute between the parties that the same represents interest income derived from FDRs with nationalised bank.

There is further no quarrel between the parties that hon’ble jurisdictional high court’s decision (2017) Vaveru Co-operative Rural Bank Ltd. Vs. CIT (2017) 396 ITR 371 (A.P) has very much considered the Revenue’s argument placing reliance on Totgars’ Co-operative Sale Society Ltd. Vs. ITO 322 ITR 283 (SC) that such an interest income is not business income and decided it in favour of the assessee. We therefore find no merit in Revenue’s arguments supporting the CIT(A)’s detailed discussion in violation of hon’ble jurisdictional high court decision to this effect. The assessee succeeds in its sole substantive grievance therefore. No other argument has been pressed before us. 4. This assessee's appeal is allowed in above terms.