|
Advanced Search Options
Case Laws
Showing 501 to 520 of 1203 Records
-
2021 (11) TMI 703
Disallowance u/s 14A - proof of no exempt income - HELD THAT:- On going through the financial statements of the assessee, we find that the assessment had mad investments and interest was debited to P&L Account, but, suo-moto, the assessee has not disallowed any expenditure u/s 14A of the Act. Further, it was observed that there is no exempt income received by the assessee during the impugned AY - disallowance made by the AO u/s 14A r.w.r. 8D is not correct. It is a settled law that if there is no exempt income, no disallowance can be made as there are Catena of judgements of Hon’ble Tribunal that if there is no exempt income, no disallowance can be made u/s 14A of the Act. Therefore, we uphold the order of CIT(A) in deleting the disallowance made u/s 14A rwr 8D of the Act. Thus, the ground raised by the revenue on this issue is dismissed.
Disallowance of expenditure in respect of bogus sub-contracts - AO observed that a survey u/s 133A was conducted by the ADIT, Unit – I, in which certain bogus sub-contract expenses came to light - HELD THAT:- CIT(A) accepted that the payments made by way of cheques and the TDS made on the payments made to sub-contractors. However, the CIT(A) has not examined the genuineness of the works undertaken by the sub-contractors and he did not examine any other related documents for substantiating sub-contract works done by the sub-contractors. Merely considering that the TDS was deducted on the payments made to sub-contractors is not sufficient reason to delete the addition. We also find that the CIT(A) brushed aside the objections raised by the AO in his order. Therefore, keeping in view the findings recorded by the AO and in the interest of justice, we remit this issue back to the file of the AO with a direction to examine the additional evidences filed by the assessee before the CIT(A) and decide the issue in accordance with law after providing reasonable opportunity of being heard to the assessee in the matter. Thus, this ground is treated as allowed for statistical purposes.
Addition towards excess debit - AO observed that the total purchases on which TCS made is less that the purchase of liquor debited in the P&L Account and excess which was added back to the total income - CIT-A delete the addition - HELD THAT:- While deleting the addition made by the AO, the categorical finding of the CIT(A) is that The AO was not justified in not considering the Form 26AS of the appellant company wherein the purchase of liquor by the appellant from A.P. Beverages Corporation Limited (APBCL) is evident. Therefore, we do not find any reason to interfere with the order of the CIT(A) and upholding the same, we dismiss the ground raised by the revenue on this issue.
-
2021 (11) TMI 702
Scope of Deposit Credit Guarantee Corporation of India Act [DICGCI] - Overriding title on income in favour of DICGCI - accrual of income - Assessee is a cooperative bank and under liquidation - assessee has received the amount of interest income net of expenses in the year under consideration post liquidation - liability of the appellant assessee for repayment to the depositors and DICGC from the recovery made by it from the borrowers against the interest received from the fixed deposit, which has accrued on the amount recovered pending the payment to the depositors. - HELD THAT:- As decided in The Visnagar Nagrik Shahakari Bank Ltd. & Ors. [2015 (7) TMI 1390 - GUJARAT HIGH COURT]whatever amount will be received by the assessee has to be paid firstly to DICGCI after making necessary provision for expenses in relation to liquidation and declaration of dividend. Thus, there remains no ambiguity to the fact that the assessee has no right in the impugned amount of interest income as the same has been diverted to DICGCI as discussed above. Accordingly, the amount of interest though received by the assessee but does not belong to it.
The amount of interest in dispute is not an income of the assessee and therefore the same cannot be made subject matter of tax in the hands of the assessee - Decided in favour of assessee.
-
2021 (11) TMI 701
Disallowance by relying on CBDT Circular No. 5/2012 r.w explanation 1 to Sec. 37(1) - scope of regulations issued by Medical Counsel of India - claim of marketing & promotional activity under the selling and distribution expenses u/sec. 37(1) - HELD THAT:- We find that the facts of the present case are similar and identical to the above decision in respect of sales promotional expenses claimed in the profit and loss account. The Hon’ble Tribunal in the ARISTO PHARMACEUTICALS P LTD. [2019 (7) TMI 862 - ITAT MUMBAI] has considered the provisions of law, facts and circumstances, CBDT circular, MCI guidelines and granted the relief to the assessee. Accordingly, we follow the judicial precedence and set aside the order of the CIT(A) to the extent of disallowance of sale promotion expenses incurred by way of gifts, freebies, travel allowance and monetary grants and direct the Assessing Officer to delete the addition and allow the ground of the appeal of assessee.
-
2021 (11) TMI 700
Addition u/s 68 unexplained cash credit - profit/income of the assessee from sale of paddy - HELD THAT:- Section 68 of the Act is attracted (a) when the assessee fails to prove the genuineness of the transaction that has entered into his book of accounts; (b) when there is no satisfactory explanation provided on the part of the assessee to the AO with respect to the amount credited into the accounts; & (c) when there are documentary evidences required to support the validity of the amount credited but there are no such documents furnished by the assessee.
The assessee has provided the confirmation letter of the purchaser of paddy M/s. Rameswar Agro Industries Pvt. Ltd., alongwith its ledger account to support that the purchaser had purchased paddy and paid the amount. It is not in dispute that the assessee has not maintained any books of account and whatever credit entries are found by the AO, it was from the bank accounts of the assessee in which deposits were made at different point of time. Even passbook issued by the bank cannot be termed to be the books of account of the assessee in the case of Bhai Chand N. Gandhi [1982 (2) TMI 28 - BOMBAY HIGH COURT] - Therefore, provisions of section 68 of the Act cannot be invoked on various deposits/credit found recorded in the bank account of the assessee in absence of books of the assessee maintained for that previous year.
The assessee submitted confirmation from the purchaser of paddy before the authorities below and this was the best possible evidence under his command to establish that the impugned amount was actually sale proceeds of paddy, which was purchased from open market/farmers and sold the same without maintaining any books of account to M/s. Rameswar Agro Industries Pvt. Ltd. Even as a man of ordinary prudent, one cannot disagree with the contention of the assessee that even if he is a director in the purchase company i.e. M/s. Rameswar Agro Industries Pvt. Ltd., he cannot be refrained from making sale of paddy to the company in which he is a director.
Cautious about the provisions of section 40A(2) & (3) of the Act, wherein, the department has right to examine the expenses and payments made to related parties by the related parties but it is not the allegation of the AO in the present case.
We not in agreement with the contention of Ld. DR that if sale has not been shown by the assessee in the return of income, then entire amount has to be taxed in the hands of the assessee as his income because if purchase and sale, both transactions have been undertaken without maintaining books of account then only profit element received by the assessee inclusive of sale proceeds can be taxed as income of the assessee because the assessee has to be given credit of the amount incurred for purchase of goods which was sold by him against receipt of sale consideration. A.R. relied on the decision of case of CIT vs. P. Sathyanarayan P. Rathi, [2013 (6) TMI 257 - GUJARAT HIGH COURT] wherein, it has been held that only the profit element and not the entire amount of the purchases can be added to the income of the assessee.
We deem it just and proper and reasonable to cover all possible leakage of revenue, to tax only profit element embedded in the sale proceeds received and deposited by the assessee in the bank account. In view of facts stated above, thus direct the AO to tax 10% of the total impugned amount as profit/income of the assessee from sale of paddy and to delete the remaining amount. Appeal of the assessee is partly allowed
-
2021 (11) TMI 699
Condonation of delay in filing appeal - delay of 779 days in filing the appeal - no cause, much less sufficient cause, shown by the appellant to explain the inordinate delay in filing the appeal - HELD THAT:- The Tribunal after taking note of the statutory provisions took note of the decisions of the Tribunal, CESTAT West Zonal Bench, Mumbai in the case of COMMR. OF C. EX. & CUS., AURANGABAD VERSUS COSMO FILMS LTD. [2014 (12) TMI 315 - CESTAT MUMBAI] and allowed the assessee’s case. The said decision was in respect of another assessee who are engaged in the same process of manufacture namely manufacture of BOPP Films. The Tribunal took note of the decision. The Tribunal followed the case of MRF LTD. VERSUS COLLECTOR OF CENTRAL EXCISE, GOA [1998 (11) TMI 233 - CEGAT, NEW DELHI] and SUPREME INDUSTRIES LTD. VERSUS COMMISSIONER OF CENTRAL EXCISE, MUMBAI-III [1997 (3) TMI 529 - CEGAT, MUMBAI], which was upheld by the Hon’ble Supreme Court in COMMISSIONER VERSUS SUPREME INDUSTRIES LTD. [1998 (3) TMI 676 - SC ORDER] wherein it was held that by taking credit the inputs do not become non-duty paid.
There is nothing on record to indicate that those decisions of the Tribunal have been reversed or modified by the High Court or by the Hon’ble Supreme Court. That apart, we find that the conclusion arrived at by the Tribunal examining the nature of manufacturing activity done by the respondent assessee and the fact that the Polypropylene Granules which were procured being admittedly duty paid items, the bye-product which is generated during the course of manufacture can never be treated as a non-duty paid item. Therefore, the conclusion arrived at by the Tribunal does not call for any interference.
The substantial questions of law are answered against the Revenue - Appeal dismissed.
-
2021 (11) TMI 698
Finalisation of provisional assessment - time limitation - It is contended that the time limit for finalisation of the provisional assessment is stipulated as two months under the Regulations and already more than six months have elapsed without such finalisation - HELD THAT:- There will be a direction to the competent amongst the respondent to consider and pass appropriate orders finalising the provisional assessments, pursuant to bills of entry listed in Ext.P1, within a period of 30 days from the date of production of documents by the petitioner and after hearing the petitioner.
Petition allowed.
-
2021 (11) TMI 697
Refund of Customs Duty paid - denial on the ground that the appellant had not filed any appeal against the 26 orders of final assessment order for finalizing provisional assessment - HELD THAT:- The learned counsel has made reference of Section 154 of Customs Act, 1962 whereby the assessment can be amended by Reassessment of Bill of Entry. However, on query from the bench learned counsel fairly submits that they have not filed any application under section 154 of the Customs Act, 1962. In this position, in the interest of the justice the appellant should be given an opportunity to pursue their case in terms of section 154 of Customs Act, 1962.
The appellant is directed to make an application under section 154 of the Customs Act, 1962 for Re- assessment of Bills of Entry. The Proper officer shall consider the application to be made under section 154 of the Customs Act, 1962 in accordance with law - the appeal is disposed of by way of remand to the Original Authority.
-
2021 (11) TMI 696
Revocation of CHA License - Forfeiture of security deposit - levy of penalty - it is the contention of Learned Counsel that the proceedings were conducted behind the back of the licensee, that there are no findings recorded by the inquiry authority - principles of natural justice - HELD THAT:- The procedure prescribed under regulation no. 22 of Customs House Agents Licensing Regulations, 2004 envisages a specific role for the Inquiry Authority in the process elaborated therein. This, doubtlessly, presumes the participation of the customs house agent. It is on record that these procedures were not followed and the conclusion had been arrived at on presumed admission as reported by the Presenting Officer. The ostensible reason for such summary conclusion was the ‘non-availability’ of the licensee at the licensed address - Without examining the legality of continuance of proceedings after the nominated official ceased to be Deputy/Assistant Commissioner of Customs, the absence of any record evincing that licensee had been placed on notice about acquiescence of the Commissioner of Customs with the re-designated official carrying out the entrusted task may well have been the reason for non-acceptance of communication emanating from an address that could, conceivably, alarm the appellant herein.
It is on record that the alleged breach of obligations were grounded in the proceedings initiated under Customs Act, 1962 at Faridabad and the closure thereof erases the foundation on which the customs house agent was issued with the charge-sheet. Furthermore, a customs house agent is licensed under the authority of section 146 of Customs Act, 1962 in terms of which the agency function should commence with declarations filed under section 46 or section 50, as the case may be, of Customs Act, 1962 - The absence of seals and the discrepancy in weight pertained to containers delivered at the designated place of export before the shipping bill was filed; these occurred prior to the statutory responsibility thrust upon the customs house agent could be said to have commenced. Furthermore, the licensing authority failed in ascertaining the extent of responsibility as it is evident that the custodian had been derelict in accepting such consignments or that such deliveries were conventionally accepted in the said jurisdiction.
The incident which gave rise to the proceedings occurred in January 2011 and the proceedings took one full year thereafter to commence. The role of the customs house agent in the alleged breach of procedure was also found to be condonable in adjudication proceeding - Appeal allowed - decided in favor of appellant.
-
2021 (11) TMI 695
Valuation - Works contract service - Composition scheme - case of the Revenue is that since the appellant could not ascertain the actual value of goods transferred, it should have paid service tax under composition scheme - where the value of the works contract is split notionally into value of goods and value of services as per the State Act and Rules and VAT has been paid on the goods component on which and there is no break-up of the actual value of the goods which are transferred or deemed to have transferred in execution of the contracts, can service tax also be charged on the same amount?
HELD THAT:- In this case in view of the Tamil Nadu VAT Act and Tamil Nadu VAT Rules (which were also in existence prior to 01.07.2012 also) the appellant is bound to pay VAT on 70% of the value of the indivisible works contract deeming it to be the value of the goods transferred. It is undisputed that the appellant paid VAT accordingly and paid service tax on the remaining 30% - Since the works in this case were not original works, it falls under category B of clause (ii) of this Rule and service tax should be paid on 70% of the value of the works contract. In other words, if the Revenue’s argument is accepted, the appellant will have to pay service tax on 70% of the gross amount charged for the works contract and the appellant has already paid VAT on 70% of the gross amount charged as per the Tamil Nadu VAT Act. This will lead to an anomalous situation where the appellant has to pay VAT as well as service tax on 40% of the total value of the works contract.
Where the value has already been split as per the state law and VAT has been paid on the goods component of the composite works contract, no service tax can be levied on such component again taking recourse to Rule 2A(ii) of Service Tax (Determination of Value) Rules, 2006. The demand for the period post 01.07.2012 also needs to be set aside on this ground. Since the demand of service tax does not sustain, the demand of interest under Section 75 and imposition of penalty under Section 76, 77 and 78 do not also survive.
The impugned order is set aside - Appeal allowed - decided in favor of appellant.
-
2021 (11) TMI 694
Valuation - tenancy agreement - doctrine of merger - inclusion of notional interest received on the security deposit taken - contravention to the Explanation (a) to Section 67 of FA - HELD THAT:- The issue decided in appellant own case M/S VIKHROLI CORPORATE PARK VERSUS COMMISSIONER OF SERVICE TAX, MUMBAI [2016 (12) TMI 484 - CESTAT MUMBAI] where it was held that an agreement between the appellant and his customer provides for interest free security deposit, which is nothing but advance, Revenue cannot state that such security deposit will earn interest, and notional interest needs to be taxed.
Since the Civil Appeal filed by the Revenue challenging the order of the Tribunal has been dismissed by the Hon’ble Apex Court stating that there are no grounds to entertain this appeal, the doctrine of merger applies the order of the Tribunal and gets merged in that of the Hon’ble Apex Court.
There are no merit in the impugned order - appeal allowed - decided in favor of appellant.
-
2021 (11) TMI 693
Refund of unutilised cenvat credit - disallowance for want of nexus - N/N. 27/2012-CE(NT) dt. 18/06/2012 - HELD THAT:- It is settled that with effect from 01/04/2011, the Board has itself done away with the nexus test vide its Notification No.27/2012-CE(NT) dt. 18/06/2012, and hence the disallowance for want of nexus cannot sustain. This view has been expressed in many orders of CESTAT benches, the latest one being of this very bench in the case of SAMSUNG R AND D INSTITUTE INDIA BANGALORE PVT. LTD. VERSUS COMMISSIONER OF CENTRAL TAX, BENGALURU EAST [2021 (3) TMI 1002 - CESTAT BANGALORE]. To this extent therefore, the impugned order is set aside.
It is now required to examine whether the reduction of utilised credit for domestic clearances has been done twice, or not. It is not in dispute that the appellant’s claim for refund was after reducing the utilised cenvat credit which appears to have again been reduced by the sanctioning authority in the de novo Order-in-Original. The Commissioner(Appeals) in the impugned order observed that the appellant’s claim for refund of unutilised cenvat credit was not supported by documentary evidences, which would only mean that the appellant perhaps did not properly explain the same with supporting documents as well as computations.
Matter remanded back to the file of the adjudicating authority before whom the appellant shall furnish all such evidences as well as computations to establish that it has already reduced voluntarily the utilised cenvat credit and if satisfied, the adjudicating authority shall work out the refund in accordance with law - appeal allowed by way of remand.
-
2021 (11) TMI 692
Valuation - addition of transportation charges to the sale price of the goods - nexus to sustain enhancement of turnover made by the Tribunal - HELD THAT:- In the present case also from the order of the ACST, it is plain that there was no evidence to show that the dealer had separately charged and collected the transportation charges. The impugned order of the Tribunal proceeds on surmises. Particularly the conclusion of the Tribunal that “the payment of transportation charges must be deemed to have been borne by the dealer” is unacceptable in the absence of any documentation to support such an assumption.
With there being no evidence placed on record to show that the transportation charges were in fact collected by the Petitioner, it is not possible to sustain the above conclusion of the Tribunal - the question is answered in the negative, in other words, in favour of the dealer and against the Department.
It is held that the Tribunal was not justified in directing addition of the transportation charges to the sale price of the goods under the OST Act - the order of the ACST is restored.
The revision petition is disposed off.
-
2021 (11) TMI 691
Validity of re-assessment order - enlargement of time limitation with prospective effect or not - Section 39(1) of KVAT Act - HELD THAT:- The order of re-assessment which was passed on 27.03.2013 for the Assessment Year 2005-06 is barred by limitation. It is pertinent to note that under the unamended provision, a vested right had accrued in favour of the petitioner. The amendment made to Section 40 of the Act, cannot be construed so as to open up a liability which had become barred. Therefore, even by retrospective operation of law, the aforesaid vested right accrued to the petitioner cannot be taken away.
The impugned notice dated 17.03.2013 issued by the respondent No.3 namely the Additional Commissioner of Commercial Taxes is hereby quashed - Appeal allowed.
-
2021 (11) TMI 690
Seeking permission to travel abroad for the purpose of renewing his passport - divorce petition was filed on the ground of cruelty - offences under Sections 498 and 406 IPC r/w 4 of Dowry Prohibition Act - HELD THAT:- If the presence of the petitioner is required by the trial Court, he would appear and submit to the trial Court orders. Whenever his presence is absolutely necessary, he shall appear. On the other dates, his counsel would continue with the proceedings and will not seek any adjournments or defer the cross examination for the reason that instruction is to be received from the petitioner and the presence of the petitioner is required.
The petitioner is directed to file an undertaking affidavit to that effect before the Court below. This Court directs the Regional Passport Office, Trichy to renew the passport bearing No.J4490193 and also to permit the petitioner to undertake his travel to USA - Petition disposed off.
-
2021 (11) TMI 689
Attachment of Bank Account of petitioner - section 83(1) of the CGST Act - HELD THAT:- Mr. Jetly, learned senior advocate for the respondents seeks 6 (six) months’ time to complete the proceedings. Mr. Mishra informs that the petitioner does not intend to file any further reply. In such circumstances, we expect the office of the Principal Commissionerate to proceed to decide the show-cause notice issued to the petitioner, without wasting any further time.
While rejecting the prayer of Mr. Jetly, we direct the adjudicating authority, i.e., the Additional Commissioner, to decide the show-cause notice in accordance with law and upon granting opportunity of hearing to the petitioner, as early as possible, and preferably within two months from date of receipt of a copy of this order. All contentions are left open for being urged by the petitioner before the adjudicating authority.
This writ petition shall be listed on 28th January, 2022 for reporting compliance of this order.
-
2021 (11) TMI 688
Seeking for impleadment of immediate family members of the petitioner - seized cash amount belongs to the applicants, who now seek to be impleaded - HELD THAT:- Issue notice. Ms.Nidhi Banga and Mr.Harpreet Singh, Advocates accept notice on behalf of the respondent no.1 and respondent nos.2 to 6 respectively. They pray for and are permitted to file their counter affidavits/replies to the application within three weeks. Rejoinder affidavit, if any, be filed before the next date of hearing.
-
2021 (11) TMI 687
Filing of Form Tran-1 - vires of sub-rule 1(A) to Rule 117 of CGST Rules - N/N. 48/2018 CT dated 10.09.2018 - restriction on extension of time limit only to those registered persons in respect of whom Council has made recommendation - Circular No.No.39/13/2018 dated 03.04.2018 - HELD THAT:- This Court has categorically came to the conclusion that the CGST provisions more particularly relating to filing and uploading of Forms is a transitory provision and on account of the same, a beneficial treatment has to be extended to the assesse so as to permit the assessee to make his filings and obtain any input credit if so entitled.
Though the allegations and counter allegations have been made as regards uploading or non-uploading, ability to upload and inability to upload, the fact remains that, what is sought to be uploaded are relating to transactions which occurred prior to 27.12.2017 which are evidenced by records including transactions carried out through normal banking channels. It is these transactions which have already occurred prior to the introduction of GST regime which are sought to be filed by uploading the Form in Tran- 1. More so because there is a new procedure which has been prescribed and new methodology which has been adopted for the assessment etc., an assessee cannot be deprived of any input credit that he may be entitled to only on account of non-uploading of a particular form - If the assessee is deprived of benefits on such technical grounds, there would be no purpose in having the tax system, which would result in the assessee trying to evade taxes.
There would be no requirement for issuance of Certiorari to quash Sub-Rule 1A to Rule 117 of CGST or Rule 17 inserted by notification No.48 or the circulars issued as sought for - A mandamus is issued directing the respondent authorities to open the portal to enable the petitioner to upload the necessary forms, if the portal cannot be opened to permit the assesse to file hard copies of the said form and act thereon.
-
2021 (11) TMI 686
Additional depreciation @20% under Section 32(1)(iia) - assessee which generates electricity from thermal power is entitled for additional depreciation OR not? - HELD THAT:- In the State of Andhra Pradesh vs. National Thermal Power Corporation [2002 (4) TMI 694 - SUPREME COURT] held that electric energy can be transmitted, transferred, delivered, stored, possessed etc. in the same state as movable property. The Hon’ble Supreme Court followed its earlier decision in Commissioner of Sales Tax, Madhya Pradesh, Indore vs. Madhya Pradesh Electricity Board, Jabalpur [1968 (11) TMI 85 - SUPREME COURT]. Therefore, the revenue cannot dispute the fact that the electricity needs to be construed as a movable property as it being capable of being transmitted and transferred etc.
Whether the respondent/assessee would be entitled to additional depreciation under Section 32(1)(iia)? - We are guided by the decision of this Court in the case of Commissioner of Income Tax, Kolkata-I vs. Ankit Metal and Power Limited [2015 (8) TMI 566 - CALCUTTA HIGH COURT] as followed the decision of Hi-tech Arai Limited [2009 (9) TMI 60 - MADRAS HIGH COURT] and CIT vs. VTM Ltd. [2009 (9) TMI 35 - MADRAS HIGH COURT] and held that the assessee therein which was also engaged in the activity of manufacturing of power is entitled for additional depreciation under Section 32(1)(iia) of the Act. To the same effect, there are several other decisions of other High Courts and the latest being in the case of PCIT, New Delhi vs. NTPC SAIL Power Co.(P.) Ltd. . [2019 (3) TMI 207 - DELHI HIGH COURT]
We hold that the respondent/assessee is entitled for additional depreciation under Section 32(1)(iia) - Decided in favour of assessee.
-
2021 (11) TMI 685
Nature of receipt - Interest derived from Short Term Deposit Receipts - revenue or capital receipt - HELD THAT:- In the present case, the facts are akin to the decision in Karnal Co-operative Sugar Mills Ltd.[1999 (4) TMI 7 - SC ORDER]. Factually it is seen that the interest earned on the STDR was towards reducing the cost of the capital assets and therefore should not have been treated as revenue receipt in the hands of the Assessee.
Consequently, the question framed is answered in affirmative, i.e. in favour of the Assessee and against the Department. In other words, it is held, in the facts and circumstances of the case, that the interest earned from STDRs made by the Appellant to enable to open LoC for procuring plant and machineries is incidental to such acquisition and should be treated as receipt of a capital nature and not taxed as income.
-
2021 (11) TMI 684
Benefit of exemption u/s 11 - Whether Tribunal erred in treating the assessee as a charitable institution, even when the activities of the assessee fell under the last limb of Section 2(15)? - HELD THAT:- The assessee/society is running a printing press and publishing a newspaper. The profit so generated is used for charitable purposes and apparently there is no profit motive in the activities of the assessee. As such it cannot be said that the assessee is involved in any trade, commerce or business. Consequently, the mischief of Proviso to Section 2(15) of the Act is not attracted.
The assessee/society is charitable in nature as the profit, if any, made by the assessee/society is being ploughed back for charitable activities. Further, the appellant itself has granted the assessee registration under Section 12A, recognition under Section 10(23C)(vi) and Exemption under Section 80G of the Act.
This Court is in agreement with the findings of the CIT(A) and ITAT that the assessee/society does not carry on any business, trade or commerce with the intent of earning and distributing profit. Appeal dismissed.
............
|
9911796707
