SHI vs. Amruddhi Nagari Sahakari Patasanstha Maryadit, Mumbai
In the result, appeal filed by the Assessee stands allowed in the aforesaid terms
ITA 2225/MUM/2023[2020-21]Status: DisposedITAT Mumbai30 Oct 2023AY 2020-21
Bench: Shri N. K. Choudhry, Jm
For Appellant: Ms. Smitha V. Nair, Ld. DRFor Respondent: Date of Hearing
Section 2(24)(viia)Section 250Section 5Section 56Section 80PSection 80P(2)(a)Section 80P(4)
deposits collected and income generated thereof which is in the nature of banking business.
1. By virtue of inclusive definition of income in section 2(24)(viia), providing credit facilities by a co-operative society with its members are to be included as profits and gains of business of banking ... facts and circumstances, the assessee is clearly not eligible for deduction u/s 80P(2)(a)(i) in view of the specific provisions of section 2(24)(viia) read with Explanation to 80P(4) of the Income
Tax Act, 1961 inserted w.e.f. 01.04.2007.”
4. The Assessee being aggrieved challenged the said