IN THE ITAT PUNE BENCH

INTURI RAMA RAO, A.M.

T.S. Nagari Sahakari Patsanstha Maryadit v. ITO

ITA No. 433/PUN/2024

15 April, 2024

Assessee by: Premchand C. Patil and Yuvraj Bhandare

Revenue by: Arvind Desai

Inturi Rama Rao, A.M.

This is an appeal filed by the assessee directed against the order of the National Faceless Appeal Centre, Delhi (NFAC) dated 23-12-2023 for the assessment year 2018-19.

2. Briefly, the facts of the case are that the appellant is a Cooperative credit society engaged in providing credit facilities to its members. The Return of Income for the assessment year 2018-19 was filed on 22-8-2015 declaring total income of Rs. Nil after claiming exemption under section 80P(d)(a)(i)/80P(2)(d) of the Income Tax Act, 1961 (the Act) of Rs. 26,73,789 and offered the income of Rs. 30,350 to tax. The case was selected for Limited Scrutiny to examine the (i) Investments/Advances/Loans and (ii) Deduction from total income under Chapter VI-A. The assessment was completed by the assessing officer vide order dated 2-3-2021 passed under section 143(3) read with section 143(3A) & 143 (3B) of the Act determining total income at Rs. 9,70,022. While doing so, the Assessing Officer had brought to tax the interest earned on FDs with other co-operative banks holding that the said interest does not qualify for deduction under section 80P(2)(a)(i) of the Act.