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Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that the interest on securities, subsidies received from the Government and dividend business income of the assessee entitled to deduction under s. 80P(2)(a)(i) of the IT Act, 1961 ?

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Sec. 56 & 80P(2)(a)(i) of Income-tax Act, 1961— Deduction—If one has to go by the definition of ‘co-operative bank’, the assessee does not get covered thereby and it is also a matter of common knowledge that in order to do the business of a co-operative bank, it is imperative to have a licence from the Reserve Bank of India, which the assessee does not possess and the Reserve Bank of India has itself clarified that the business of the assessee does not amount to that of a co-operative bank, therefore, the assessee would not come within the mischief of sub-s. (4) of s. 80P, hence the principle of mutuality that was relied upon by the assessee was rejected as being inapplicable to its case — SARAVANAMPATI PRIMARY AGRICULTURE CO-OPERATIVE CREDIT SERVICE LTD. Vs. ITO  [2020] 313 CTR 459 (MAD)

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