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TMI Blog2019 (3) TMI 359X X X X Extracts X X X X X X X X Extracts X X X X ..... tant appeal suffers from 13 days delay in having stated to be attributable to various procedural aspects. The Revenue is fair enough in not disputing the correctness thereof during the course of hearing. I thus condone the impugned 13 days delay to be neither intentional nor deliberate. The case is now taken up for adjudication on merits. 3. The assessee's sole substantive ground challenges the CIT(A)'s action affirming the assessment findings amounting to Rs.7,02,495/- as under:- "4. _नणंय / Decision: 4.1 Grounds 1-3 As all the grounds relates to the lone effective issue of disallowance of deduction of interest for a sum of Rs. 7,02,495, the same are considered together. During the assessment proceedings the AO ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m the assessment order. Beyond this, from the submissions made during the appellate proceedings, the appellant has not unequivocally proved as to its exact nature of activities by providing memorandum of objectives, rules and by-laws of the society, detailed annual report, registration documents, list of members and beneficiaries. It has also not submitted any details as to whether it is a primary co-operative society or a federated co-operative society and whether credit facilities have been provided to or accepted from only members or also including non-members by way of any documentary evidences other than mere assertions. Given the fact that the ao asked a pointed explanation from the appellant as to why and how the provisions for inter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ry and nominal members, that the appellant sticks to the principle of mutuality by restricting its business of providing credit facilities to members only and that the appellant is not a federated society, the AO was justified in disallowing the interest claim on account of provisions. Appellant's ground fails." 4. I have given my thoughtful consideration to rival contentions. It transpires during the course of hearing that no exempt income has been derived at the assessee's behest in the impugned assessment year. I put a specific query as to whether the assessee had claimed any 80P deduction or not in the impugned assessment year. Learned counsel has filed before me assessee's computation of income, return as well as acknowledgement of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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