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Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)
13. The PCIT has observed that the contention of the assessee is totally opposite to the plea taken during the assessment proceedings where the assessee had claimed deduction under section 80P(2)(a)(i) and not under section 80P(2)(d); that any cooperative bank other than a ITA 515/CHD/2017 ITA 569/CHD/2018 & ITA 645/CHD/2019 21 primary agricultural credit society