ORDER

PER OM PRAKASH KANT, AM

This appeal by the assessee is directed against the order dated 11.12.2025 passed by the Ld. Commissioner of Income-tax (Appeals) Act - National Faceless Appeal Centre (NFAC), Delhi [Ld. CIT(A)] for A.Y. 2020-23, raising following grounds:

“1. On the facts, in the circumstances of the case and in law, the learned Commissioner of Income Tax (Appeals), National faceless Appeal Centre (NFAC) [CIT(A)'s], erred in upholding disallowance of Rs. 20,58,658/- claimed as deduction claimed u/s 80P(2)(d) of the Income Tax Act, 1961, ['the Act'] being interest income earned on deposits with co-operative banks/societies, thereby denying the legitimate benefit available to a Co-operative Housing Society.

2. The Ld. CIT(A) erred in holding that the interest income does not qualify for deduction u/s 80P(2)(d), ignoring the plain language of the provision which explicitly allows deduction on interest or dividends on securities, deposits, loans or advances made by the assessee co-operative society to other co-operative societies, without any restricti