CH KITTUR TALUK PRATHMIK SHALA SHI vs. HAK KIYAR PATTIN SAHAKAR SANGH NY,KITTURVS.WARD-1, BELAGAVI

ITA 299/PAN/2026Status: DisposedITAT Panaji21 August 2026AY 2021-224 pages
AI SummaryAllowed

What were the facts?

The assessee claimed deduction under Section 80P(2)(a)(i) for interest income. The AO disallowed this, treating cash withdrawals from a bank as interest income. The CIT(A) confirmed the AO's order.

What did the Tribunal hold?

The Tribunal found that the TDS was deducted under Section 194NF for cash withdrawals, not Section 194A for interest income. The bank statement also supported this. Therefore, the addition was deleted.

What were the issues?

Whether cash withdrawals from a bank, subject to TDS under Section 194NF, can be treated as interest income eligible for deduction under Section 80P(2)(a)(i).

Which sections of the Income-tax Act were involved?

Section 80P(2)(a)(i),Section 194N,Section 194A,Section 194NF

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PANAJI BENCH, ‘SMC’ PANAJI

Before: DR.MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri Vijay R. Chappar, CA
For Respondent: Shri Mayur Kamble
Hearing: 18.08.2026Pronounced: 21.08.2026

PER DR. MANISH BORAD, ACCOUNTANT MEMBER :

The captioned appeal at the instance of assessee pertaining to A.Y. 2021-22 is directed against the order dated 02.03.2026 framed by National Faceless Appeal Centre, Delhi arising out of Assessment Order dated 23.12.2022 passed u/s.143(3) r.w.s.144B of the Income Tax Act, 1961 (in short ‘the Act’).

2

2.

Assessee raised grounds of appeal against the disallowance u/s.80P(2)(a)(i) of the Act for the alleged interest earned from Nationalised Banks. Assessee has also raised various other legal issues viz., (1) Erroneous Addition based on system mismatch in AIS; (2) Failure to recognize the True Na

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 80P(2)(a)(i)

All 2,331 judgments and leading authorities on Section 80P(2)(a)(i) →

Recent GST High Court judgments

Search GST case law →