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In favour of assessee.On the facts and circumstances of the case and in law, the Ld.CIT(A) has erred in allowing the assessee a deduction of Rs.52,12,193/- u/s.80P(2)(a)(i) of the Income-tax Act, 1961.

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Section 80P of the Income Tax Act, 1961 — Deduction — Assessee, a co-operative credit Society had not undertaken any of banking business activities and was providing financial assistance to its members only and not to general public. it would be hit by provisions of section 80P and thus was entitled to deduction under section 80P(2)(a)(i) — Mahapalika Kshetra Madhyamil Shikshak Sahakari Patsanstha Maryadit vs. Income tax Officer [2020] 180 ITD 267 (Mumbai-trib)

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