Section  80P(2)(d) of Income Tax Act, 1961—Deduction—Section 80P(2)(d) allows whole deduction of an income by way of interest or dividends derived by the co-operative society from its investment with any other co-operative society and this provision does not make any distinction in regard to source of the investment because this Section envisages deduction in respect of any income derived by the co-operative society from any investment with a co-operative society. it is immaterial whether any interest paid to the co-operative society exceeds the interest received from the bank on investments and the Revenue is not required to look to the nature of the investment whether it was from its surplus funds or otherwise and the Act does not speak of any adjustment as sought to be made out by learned counsel for the Revenue. The provision does not indicate any such adjustment in regard to interest derived from the co-operative society from its investment in any other co-operative society, therefore, Tribunal was right in law in allowing deduction under Section 80P(2)(d) in respect of interest of Rs. 4,00,919 on account of interest received from Nawanshaln Central Co-operative Bank without adjusting the interest paid to the bank —  Surat Vankar Sahakari Sangh Ltd. vs. Asstt. CIT [2020] 421 ITR 134 (GUJ)