2018 (8) TMI 1839

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....ective orders of the CIT(A) concerning AYs. 2011-12 & 2012-13. ITA No. 3023/Ahd/2014 - AY 2011-12 2. The grounds of appeal raised by the assessee reads as under: "1. The learned C.I.T. (Appeals) erred both in law and on facts in confirming the disallowance of Rs. 6,84,95,000/- being amount transferred to reserve fund u/s.67 of Gujarat Co. Op. Societies Act. On the facts of the case and in law, the deduction of the aforesaid amount ought to have been given. It be so held now and the said amount be allowed as claimed."   3. When the matter was called for hearing, learned AR for the assessee fairly submitted that the issue raised by the assessee against the order of the CIT(A) has been adjudicated against the assessee by....

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....the result, appeal of the assessee in ITA No.3023/Ahd/2014 is dismissed. 7. We shall now turn to Revenue's appeal in ITA No.3220/Ahd/2014. ITA No.3220/Ahd/2014 - 2011-12 8. The solitary ground of appeal raised by the Revenue contesting the order of the CIT(A) reads as under:  "1. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in deleting the addition of Rs. 8,24,94,000/- on account of Co-op. Development Expenses which includes breed improvement expenses without appreciating the fact that such expenditure is not connected with the ordinary course of business of the assessee and that the Co-operative Development Expenses are of enduring nature and therefore they are capital in nat....