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    <title>2026 (4) TMI 629 - ITAT SURAT</title>
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    <description>Payments made towards sugarcane purchase price were found, on the facts, to have been made to members rather than nominal members, so the Tribunal treated the distribution as arising in the course of co-operative activity and saw no basis to disturb the first appellate authority&#039;s relief. The same factual position applied in the later assessment year, with no distinguishing feature shown, so the Revenue&#039;s challenge to the deletion of additions and disallowance, including the claim under section 80P(2)(d), failed and the deletions were sustained.</description>
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