2024 (4) TMI 1134

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....e common and identical. Accordingly, the grounds raised by assessee for A.Y. 2017-18 are only reiterated as under for convenience: "1. The orders of the authorities below in so far as they are against the appellant are opposed to law, equity, weight of evidence, probabilities, facts and circumstances of the case. 2. The learned CIT[A] is not justified in upholding the assessment of a sum of Rs. 62,20,435/- being the interest earned by the appellant on deposits made with cooperative banks under the head "Other Sources" and thereby upholding the denial of deduction claimed u/s. 80P[2][a] [vii] of the Act on the ground that the said interest income earned by the appellant was not attributable to the business under the facts a....

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....llowance for cost of funds / expenditure is allowable in order to correctly arrive at income to be assessed and therefore the income assessed is excessive and liable to be reduced substantially. 5. Without prejudice to the right to seek waiver before the Hon'ble DG/CCIT, the appellant denies itself liable to be charged to interest u/s. 234-B and 234-C of the Act, which requires to be cancelled under the facts and in the circumstances of the appellant's case. 6. For the above and other grounds that may be urged at the time of hearing of the appeal, your appellant humbly prays that the appeal may be allowed and Justice rendered and the appellant may be awarded costs in prosecuting the appeal and also order for the re....

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....erest income. 3.4 Aggrieved by the orders of the Ld.CIT(A)/NFAC, assessee is in appeals before this Tribunal. 4. We have heard the contentions advanced by both sides in the light of records placed before us. 5. The Ld.AR submitted that the NFAC did not consider the decisions of Hon'ble Supreme Court in case of Mavilayi Service Cooperative Bank Ltd. v. CIT reported in 431 ITR 1 and various other decisions which has been passed subsequent to the impugned orders, by Hon'ble Supreme Court in case of Kerala State Co-operative Agricultural and Rural Development Bank Ltd. KSCARDB vs. The Assessing Officer, Trivandrum & Ors. in Civil Appeal Nos. 10069 of 2016 dated 14.09.2023. He therefore submitted that, the issue needs to be readjudicate....