Mehsana District Central Co-Operative ... vs Income-Tax Officer

The Supreme Court held that income derived from hiring out safe deposit vaults is part of the ordinary banking business under Section 6(1)(a) of the Banking Regulation Act, 1949, and thus deductible under Section 80P(2)(a)(i) of the Income-tax Act, 1961. The Court restored the matter to the Commissioner (Appeals) for fresh consideration regarding the income from voluntary reserves, emphasizing the need for the assessee to present evidence. The appeals were allowed, and the previous judgment was set aside.