2023 (5) TMI 698

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....DR ORDER This appeal is filed by the Assessee against order dated 24.02.2023 passed by the CIT(A), National Faceless Appeal Centre (NFAC), Delhi for the Assessment Year 2017-18. 2. The Assessee has raised the following grounds of appeal :- "1. The learned CIT(A) has grievously erred in law and on facts in confirming disallowance of interest received on FDRs with the Ahmedabad Dis....

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....submitted to him vide submission dated 02.04.2022 directing the allowance of interest on FDR with ADC Bank. 5. On the facts of the assessee society, the NIL return of income ought to have been accepted without any addition. 6. He has erred in law and on facts in confirming levy of interest u/s.234A, 234B, 234C and 234D as applicable without furnishing the computation sheet." 3....

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....r, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee. 5. The Ld. AR submitted that the Ahmedabad District Co-operative Bank Limited is a registered Co-operative Society under Societies Registration Act and, therefore, the decision of Hon'ble Gujarat High Court in case of Surat Vankar Sahkari Sangh Limited vs. ACIT, 72 Taxmann.com 169 (Gujarat) as well ....

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.... CIT(A) has distinguished other decisions quoted by the assessee. The Ld. DR further submitted that provisions contained in Section 80P(2)(a)(i) and 80P(2)(d) is different and, therefore, the decision of Hon'ble Gujarat High Court will not be applicable in the present case. 7. Heard both the parties and perused all the relevant material available on record. It is undisputed fact that the Ahmeda....