The Income Tax Officer held that the investments were made out of reserves and disallowed the claim.
33 lakhs and the circulating capital was about Rs 22 lakhs and held that the investment was out of the Reserve Fund.
On appeal, the Appellate Assistant Commissioner observed in his order that the Reserve Fund of the Assessee was about Rs.
665 to 668/bang./1981 dated 30th July 1982.
Consequently, he companyfirmed the order of the I.T.O. On further appeal, the Tribunal accepted the companytention of the assessee that interest income was attributable to the asseessees business income.
The aggrieved Revenue has preferred this appeal.
For the assessment years 197778, 1978 79 and 1979 80, the assessee claimed deduction under Section 80P 2 a of the Income Tax Act, 1961 on the income by way of interest on Government Securities and Dividends on shares of Industrial Financial Corporation.
The Tribunal followed its earlier order in I.T.A. Nos.
SRINIVASAN, J. The respondent hereinafter referred to as the assessee is a Cooperative Society engaged in banking business.
