2021 (10) TMI 100

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.... of convenience. 2. The assessee has raised the following common grounds in all the appeals:- "1. On the facts and circumstances of the case, order of the learned Commissioner of Income Tax (Appeals) dated 24/03/2019, for the AY-2011-12 is not maintainable in law. 2. On the facts and circumstances of the case, order of the learned Commissioner of Income Tax (Appeals), ought to have been allowed the appeal in full, instead of partly allowing the appeal, in the interest of justice and equity. 3. On the facts and the circumstances of the case the learned Commissioner of Income Tax (Appeals) ought to have appreciated that, the appellant society is established with the objective for marketing of agriculture produce grown by its members, p....

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.... the fact of the appellant case, thus without appreciating the judgment which is relied by the Appellant and passed order is not correct, hence the order of the CIT(A) is liable to be set aside. 7. On the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals) erred in treating a part of the commission earned from marketing of agricultural produce grown by members as non exempt income and learned CIT(A) ought to have treated entire income from commission earned from marketing of agricultural produce as exempt income. 8. Without considering the fact and merit of the case the learned CIT(A) confirming partly and disallowances made by the assessing authority and confirming interest is excessive, arbitrary and ....