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The High Court held that no substantial questions of law arose from the ITAT's order. Therefore, the present appeal was also dismissed on the same grounds.
The Tribunal held that interest income earned by the assessee from investments in a cooperative bank is not eligible for deduction under Section 80P(2)(a)(i) in view of Section 80P(2)(d). This court, following a previous judgment, found that interest income from cooperative banks is not deductible under Section 80P.
The High Court condoned the delay in filing appeals before the CIT(A), allowing the assessee an opportunity to present their case on merits. The Tribunal's order upholding the dismissal by CIT(A) was set aside.
The High Court noted that the Revenue had filed a similar appeal (ITA No. 175/2025) challenging the same ITAT order. Therefore, the present appeal was deemed unnecessary.
The Tribunal was justified in denying the deduction under Section 80P. Section 80A(5) mandates that a claim for deduction must be made in the return of income, and this requirement is not waived even if no return is filed.
The High Court held that in view of Circular No. 9/2024, appeals with a monetary limit below Rs. 2,00,00,000/- are not maintainable. Therefore, the appeal was dismissed on this ground.
The High Court upheld the Single Judge's decision, stating that the employee could claim a refund of the deducted TDS by filing income tax returns. The court directed the Income Tax Department to process the refund expeditiously.
The High Court of Karnataka noted the submission by the respondent-assessee that the dispute involved in the appeal has been settled under the Direct Tax Vivad Se Vishwas (DTVSV) Scheme. The appellants' counsel did not object to the disposal of the appeal as infructuous, provided liberty was granted to revive the appeal if necessary. Consequently, the High Court, with the liberty granted, disposed of the appeal. No specific findings on the merits of the original dispute were made, as the appeal was settled under the Vivad Se Vishwas scheme. The operative direction was to dispose of the appeal as infructuous with liberty to revive.
The High Court noted the submissions of the Revenue that the appeal was filed by oversight and that the substantial questions of law were being pressed in another appeal. The Court disposed of the present appeal.
The High Court of Karnataka, on January 5, 2026, considered the appeal filed by M/s. Ragigudda Sri Prasanna Anjaneya Swamy Bhaktha Mandali Trust. The learned counsel for the appellant filed a memo dated December 12, 2025, seeking leave of the Court to withdraw the appeal. The memo was placed on record. Consequently, the Court dismissed the appeal as withdrawn. No decision was made on the merits of the issues raised by the appellant regarding set off of excess application or deduction under Section 11(1)(d).