2017 (9) TMI 1998

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....lant : Shri Arun Raj S, Advocate For the Respondent : Shri A. Dhanaraj, Sr. D. R. ORDER PER P. K. BANSAL, V.P. In both these appeals filed by the assessee, the issue involved relates to the claim of deduction by the assessee under section 80P(2)(a)(vi) of the Act. 2. We have heard the rival submissions, carefully considered the same along with the orders of the tax authorities below....

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.... the members of the Toddy Workers Welfare Fund Board and are toddy tapers, for the toddy that are tapped and delivered by them to the society, they are paid remuneration based on the quantity of toddy delivered. On similar terms, toddy is collected from the non-members also. The bye-laws of the society shows that the main object of the society is establishment and management of the toddy shops. Th....

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....le of toddy through the society's own toddy shops. When that is the activity of the society, it cannot be said that the sum referred to in section 80P(1) entitling the society for deduction is generated out of the collective disposal of the labour of the appellant-societies. 15. The society does not dispute the correctness of the factual finding that toddy is collected from non-member....