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8 .The Grounds of Appeal raised in respect of fourth issue in the ITA.No.s.60/PAN/2025 & ITA.No.40 /PAN/2025. Page 18 of 36 Akshaya Co-Op credit society Limited & others. The fourth disputed issue, where the AO and CIT(A) has not allowed the claim of deduction under section 80P(2)(a)(i) of the Act as the cooperative society