9911796707
TMI Blog2014 (9) TMI 1280X X X X Extracts X X X X X X X X Extracts X X X X ..... nt Member For the Assessee : Shri P.K. Kochar, and Shri Jinendra Kochar. For the Department : Shri Mahesh Kumar- D.R. ORDER PER HARI OM MARATHA, J.M. : The revenue has filed appeal for A.Y. 2010-11 which is directed against the order of ld. CIT(A), dated 22.11.2013. For A.Y. 2009-10 only, the assessee has filed appeal against the order of ld. CIT(A) dated 12.03.2013. Since both the appeals p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n of income (ROI) declaring NIL income after claiming deduction of Rs. 4,03,6,695/- u/s 80P(2)(a)(i) of the Income Tax Act, 1961, 'the Act' for short. In the past, the assessee claimed and got similar deduction even in assessment orders framed u/s 143(3) of the Act. However, the A.O. has treated the assessee society as a Agricultural Rural Development Bank and after applying Explanation appen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... honour are: - 1. Whether there is any restriction in the Act that a cooperative society cannot engage itself in more than one activity as enumerated in section 80P(2)? If not, whether a Co-operative Society which is doing the business of Banking (Called as Co-operative Bank) can invest its surplus fund in another co-operative Societies in order to earn Interest/ Dividend and can show the same a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n lending activities and, therefore, the matter was restored back to the file of ld. CIT(A). Therefore, no specific ratio decidendi is revealed from this order. To the contrary, apart from assessee's own case orders in other similar cases passed by this very Bench are available. In the case of Jodhpur Sahakari Bhoomi Vikas Bank Ltd., Mandore Road, Jodhpur Vs ITO in ITA No. 78/Jodh/2014 A.Y. 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
