Interest Income Deduction Denial Reviewed: Section 263 Jurisdiction in Cooperative Societies

Ahmednagar Zilla Gramsevakanchi Sahakari Patsanstha Maryadit Vs PCIT (ITAT Pune) AO Made Proper Inquiry- Plausible View Prevails -80P Allowed: PCIT’s 263 Struck Down as Mere Change of Opinion Assessee, a cooperative credit society, filed ROI claiming deduction of ₹49,84,373 u/s 80P(2). FAO completed assessment u/s 143(3) r.w.s.144B accepting returned income. PCIT invoked jurisdiction u/s 263 holding that AO failed to verify interest of ₹8,58,563 & dividend of ₹9,00,000 earned from deposits with a District Central Co-operative Bank, contending that such income is taxable u/s 56 in v...