TaxTMI 
TaxTMI 
2024 (5) TMI 55
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.... Per: Sanjay Arora, AM This is an Appeal by the Assessee, directed against the Order dated 13.12.2022 by the Commissioner of Income Tax (Appeals), Income Tax Department [CIT(A)], dismissing the assessee's appeal contesting it's assessment under section 143(3) of the Income Tax Act, 1961 (the Act) dated 26.12.2016 for Assessment Year (AY) 2014-15. The assessee has also filed a Stay Application (....
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....d purposes, the defining attribute of a PACS, which though is irrelevant for the purpose of eligibility for deduction u/s. 80P(1) r/w s. 80P(20(a)(i), even as explained in Mavilayi Service Co-operative Bank Ltd. v. CIT [2021] 431 ITR 1 (SC). Smt. Devi, the Sr. DR, would, on the other hand, rely on the orders by the Revenue authorities. 3. We have heard the parties, and perused the material on rec....
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....e-laws, it is in the business of banking notwithstanding the area restrictions for it's operations inasmuch as the same are applicable only qua it's members. Rather, in such a case, being in the business of banking, even income on provision of credit to non-members would stand to be deductible u/s. 80P(2)(a)(i). The bye-laws of the assessee-society are not on record, neither stand referred to in t....