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Assessee has raised the ground that the Ld. CIT(Appeals) has confirmed the addition on account of provision for bad-debts, provision for interest and provision for gratuity without appreciation of fact that all these are infructuous when section 80P comes into effect.

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Sec. 80P(2) of Income Tax Act, 1961— Deduction — There is nothing in the provision of section 80P to show that the intention was to grant exemption to co-operative societies which were extending credit facilities to persons, who, though not members of the said society, were members of another co-operative society which is a member of the co- operative society seeking exemption and the meaning of the expression 'member' cannot therefore be extended to include the members of a primary co-operative society which is a member of the federated co-operative society seeking exemption and the principle of lifting the corporate veil cannot have any application in the context of the provisions contained in section 80P(2)(a)(z) - KENDRAPARA CREDIT CO-OPERATIVE SOCIETY LTD. V/s ITO - [2020] 28 ITCD Online 044 (ITAT-CUTTACK)

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