2023 (9) TMI 1468

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....ttaraj, Advocate For the Respondent : Shri V. Parithivel, JCIT (DR) ORDER PER MADHUMITA ROY, JUDICIAL MEMBER The instant appeal filed by the revenue is directed against the order dated 04.05.2023 passed by the National Faceless Appeal Centre (NFAC), Delhi arising out of the order dated 15.01.2016 passed by the ITO, Ward No. 7(2)(4), Bangalore u/s. 143(3) of the Income Tax Act, 1961 (he....

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....edecessor in the preceding year for A.Ys. 2013-14 and 2012-13 he was of the opinion that the interest income was not earned out of business carried on by the appellant credit society and thus the same was liable to be added relying upon the judgment passed by the Hon'ble Apex Court in case of M/s. Totgar Sales Credit Co-op. Society Ltd. vs. ITO, Karnataka reported in 320 ITR 238 SC. 3.1 The cas....

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....ibutable to the carrying out of the business of the appellant society and the judgment mentioned hereinabove in case of M/s. Guttigedarara Credit Co-operative Ltd. (supra) squarely applies to the facts of the present case. The ultimate prayer was to allow the income earned by the assessee. However, such contention made by the assessee was found to be not acceptable and the addition was made to the....

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....essee, however, was not been able to be controverted by the Ld.DR. 4.1 Having heard the Ld.Counsel appearing for the parties and having regard to the facts and circumstances of the case, and particularly considering the judgment passed by the Hon'ble jurisdictional High Court in case of M/s. Guttigedarara Credit Co-operative Ltd. (supra) on the identical facts and circumstances of the case, we ....