The assessee is a co-operative society engaged in the activity of providing credit facility to its members. Assessee is eligible for deduction u/s. 80P of IT Act. Assessee filed its return of Income u/s. 139(1) of the Act declaring total income of Rs. NIL after claiming deduction of Rs. 72,09,175/- u/s. 80P of the Act. That without acknowledging the facts and circumstances of the case the Ld. AO disallowed claim of deduction of Rs. 72,09,175/- made u/s. 80P of the Act.

Held: Once gross total income is income from business and profession, the nature of activity of the assessee is never shrouded with doubt, it is a natural corollary that concomitant deduction under section 80P(2)(a)(i) of the Act has to be extended. The learned CIT(A) has trudged on a wrong path by discussing about certain issues which were never in the realm of assessment.