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In the present case, the assessee has earned income from the savings bank account maintained with Bank of Baroda. Bank of Baroda is not a co-operative bank, therefore, any interest income from this bank will not qualify for grant of deduction under s. 80P(2)(a)(i) in view of the above judgement of Hon'ble Gujarat High Court as well as under s. 80P(2)(d) because it is not co-operative society. Therefore, the learned CIT(A) has rightly disallowed claim of the assessee for grant of exemption under s. 80P(2)(d) of the Act. However, we find merit in the second contention of the assessee that proportionate expenditure should be allowed in respect of interest income earned from the scheduled bank.

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Sec. 80P(2)(d) of Income-tax Act, 1961— Deduction—JAY SOMNATH CO-OPERATIVE CREDIT SOCIETY LTD. vs. ITO.[2020] 22 ITCD Online 04 (ITAT-AHMEDABAD)

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