2013 (3) TMI 652

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....r the Respondent : Mukesh M. Patel ORDER T. R. Meena (Accountant Member) These are three appeals at the behest of Revenue which have emanated from the orders of CIT(A)-XX, Ahmedabad, dated 21.09.2012 for all three assessment years. All three appeals were heard together and are being disposed of by way of this common order for the sake of convenience. The sole ground of appeal is against d....

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....tural and Rural Development bank." After analyzing both the Sections, the ld. A.O. found that the appellant is not a co-operative society neither a primary Agricultural Credit Society nor a primary Co-operative Agricultural and Rural Development Bank. The clarification issued by the CBDT is also not applicable in case of assessee. As per A.O., the amended provision is applicable on the appellan....

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....lso relied in case of Dy.CIT, Central Circle, Panaji, Goa vs. Jayalakshmi Mahila Vividodeshagala Souharda Sahakari Ltd. (137 ITD 163), ITO, Ward-1(4) Vs. Jankalyan Nagri Sahakari Past Sanstha Ltd. (24 Taxman 127), ITAT, Pune Bench & Jafari Momin Vikash Co-op. Credit Society Ltd. vs. CIT, Ahmadabad Tribunal, order dated 20.06.2012 in ITA No. 902/Ahd/2012. Ld. CIT(A) has held as under: "Kee....

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....the CIT(A) allowed the appeal partly. 4. Now the Revenue is before us. Ld. Sr. D.R. relied upon the order of the A.O., however, ld. Counsel for the appellant relied on the order of the CBDT Circular as well as various case laws cited by the appellant before the CIT(A) and requested to confirm the order of the CIT(A). 5. We have heard the rival contentions and perused the material on record. ....