AdvertisementShiroda Progressive Urban Multipurpose Cooperative Society Limited Vs ITO (ITAT Panaji)Panaji ITAT Allows Section 80P Deduction on Interest from Scheduled & Commercial Banks: Bank Deposits of Credit Co-operative Society Are Attributable to Banking BusinessThe Panaji ITAT in The Shiroda Progressive Urban Multipurpose Cooperative Society Ltd. v. ITO held that a credit co-operative society is entitled to deduction under section 80P(2)(a)(i) on interest earned from deposits/investments with scheduled and commercial banks, where such investments are attributable to its banking/credit business. The assessee, a co-operative credit society engaged mainly in banking activities, had claimed deductions aggregating ₹44.36 lakh under sections 80P(2)(a)(i) and 80P(2)(c). The Tribunal relied upon the Karnataka High Court ruling in Tumkur Merchants Souharda Credit Cooperative Ltd. and the recent Bangalore ITAT decision in Mysore University Employees Co-op Credit Society Ltd. In the said case, the Tribunal discussed the contrary views expressed by the Hon’ble Karnataka High Court in Tumkur Merchants Souharda Credit Cooperative Ltd. 80P on interest income and that of the Hon’ble Delhi High Court in Mantola Cooperative Thrift Credit Society Ltd.