2012 (12) TMI 1238

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....order dated 20.6.2012 of Ld. CIT(A)-IV, Rajkot raises the following grounds : "1. The ld. CIT(A), Rajkot has erred in law and on facts in deleting the addition of Rs. 14,35,000/- made by the AO by disallowing the expenditure incurred by the bank towards welfare of the members, without appreciating the facts brought on record by the AO; 2. On the facts of the case and in law the ld. CIT(A) oug....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the benefit of the members the same is personal in nature. 3. The ld. CIT(A) taking note of the fact that the members are an integral part of the co-operative structure of the bank who invest in the bank and also borrow from the bank was of the opinion that the welfare expenditure on its members is with the objective of appreciating their contribution to the bank and motivating them to continue t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....interest to its members. The assessee's dominant activity is carried out with the help of members of the Co-operative Society which is doing co-operative bank business. The expenditure incurred for getting medical check up of its members and distribution of mementos to the children of its members for educational achievement are essential part of business purpose of the assessee. The Hon'ble Gujara....