2021 (9) TMI 222

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....er Section 56 of the Act of Rs. 34,95,154/- on account of locker rent on presumption basis. 3. The fact in brief is that assessee has filed return of income declaring total income at Rs. 7,15,35,980/- on 19.11.2014. The case was subject to scrutiny assessment and notice under Section 143(2) was issued on 28.08.2015. During the course of assessment the AO notice that assessee has obtained deposit amounting to Rs. 4,23,65,550/- from the customers against the allotment of safe deposit vaults (lockers). The Ld. AO was of the view that other Co-operative Banks was charging rent for the locker and the same was offered for taxation. However, the assessee has not charged rent for the locker and also not given detail of interest earned on deposit r....

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....of balance sheet placed in the Paper Book it is noticed that assessee has shown the amount of safe vault deposit of Rs. 4,23,05,500/- in the liabilities side under the head deposits claiming that same was invested in working capital of bank for providing loans and making investments. It is also submitted that interest income from loan and investment was reflected in the Profit and Loss Account and Income Tax Return was filed as per profit shown in the Profit and Loss Account. The Ld. Counsel has also placed reliance was on the decision of the Coordinate Bench of the ITAT in the case of Co-op. Bank of Mehsana Ltd. vs. DCIT in ITA No. 1261/Ahd/2017 for A.Y. 2014-15 wherein the similar issue on identical facts has been adjudicated in favour of....