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Judgment
The High Court has answered against the Revenue, the following question :
"Whether, on the facts and in the circumstances of the case, the Appellate 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 u/s 80P(2)(a)(i) of the income tax Act, 1961 ?"
The very question was considered by this court in Commissioner of Income Tax Vs. KARNATAKA STATE CO-OPERATIVE APEX BANK, and the conclusion was reiterated in Mehsana District Central Co-operative Bank Ltd. Vs. Income Tax Officer, .
It is now contended on behalf of the Revenue that the decision of this court in United Commercial Bank Ltd. Vs. Commissioner of Income Tax, West Bengal, was not considered.
We do not think that it is open to the Revenue to urge, through different counsel, the same thing again and again. We are satisfied that the answer to the question has been correctly given in the decisions aforementioned and in the order under appeal.
The civil appeals are dismissed with costs.
