2013 (5) TMI 1022

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....t : Shri D. K. Singh, Sr. D.R. For the Respondent : Mrs. Arti N. Shah, A.R. ORDER PER : Anil Chaturvedi, Accountant Member These two appeals are filed by the Revenue and two C.O. are filed by the assessee are against the order of ld. CIT(A)-XX, Ahmedabad, dated 21.09.2012 for the assessment year 2007-08 & 2008-09 respectively. The Revenue's appeals & assessee's C.O. were heard together....

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....per the provisions of the law. The A.O. was of the view that the assessee was neither a Primary agriculture Co-operative Society nor a Primary Co-operative Agriculture and Rural Development Bank and accordingly it was not entitled to the deduction as per the provisions of Section 80P(2)(a)(i) of the IT Act, but was covered under the provisions of Section 80P(4). He, accordingly, computed the total....

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....,498/- made u/s.80P(2)(a)(i) of the Act. 6. Before us, the ld. Sr. D.R. relied upon the order of the A.O., whereas, on the other hand, ld. A.R. submitted that the assessee is a Co-operative Credit Society which is distinct and separate from Co-operative Bank and it cannot be said to be a Primary Co-operative Bank within the meaning of Banking Regulation Act, 1949. It was further submitted that ....

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....n case of ACIT vs. M/s.Bangalore Commercial Transport Credit Cooperative Society Ltd. in ITA No.1069/Bang/2010 for A.Y. 2007-08, order dated 08.04.2011, the decision of Panaji Tribunal in case of DCIT vs. Jayalakshmi Mahila Vividodeshagala Souharda Sahakari Ltd. (137 ITD 163), the decision of Pune Bench in case of ITO vs. Jankalyan Nagri Sahakari Past Sanstha Ltd. (24 Taxman 127) and in case of Ja....