57 orders · Page 2 of 2
The Tribunal held that the interest income earned by the assessee from deposits with a cooperative bank is eligible for deduction under Section 80P(2)(a)(i) of the Act. The addition made by the AO and sustained by the CIT(A) was directed to be deleted.
The Tribunal held that the assessee had discharged its initial burden by providing evidence of identity, genuineness, and banking channels for the donations. The Revenue failed to provide cogent material to rebut this evidence, and the addition was also considered a double taxation as the income was already accounted for.
The Tribunal held that interest earned on deposits made from operational or statutory funds, which are intrinsically connected with the business of providing credit facilities to members, is attributable to the assessee's business activity. Therefore, such interest income is eligible for deduction under Section 80P(2)(a)(i).
The Tribunal held that the reassessment proceedings were not sustainable as the issue of 'Scheme and Discount' expenses was already examined during the original assessment. Initiating reassessment based on the same material amounted to a 'change of opinion', which is impermissible.
The Tribunal followed a coordinate bench decision and a Bombay High Court ruling, holding that a belatedly e-verified return, if filed within the time specified in Section 139(4) and claiming deductions, should be considered valid for the purpose of allowing deductions. The order of the CIT(A) was quashed.
The Tribunal held that the compensation received under the BSNL VRS-2019 scheme constitutes retrenchment compensation and is eligible for exemption under section 10(10B) of the Income-tax Act, 1961, as a capital receipt not chargeable to tax without any limit. The CIT(A)'s findings were set aside.
The Tribunal held that interest earned on deposits made from operational or statutory funds, which are intrinsically connected with the business of providing credit facilities to members, is attributable to the assessee's business activity. Therefore, such interest income is eligible for deduction under Section 80P(2)(a)(i).