TaxTMI 
TaxTMI 
2024 (7) TMI 429
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....-17, 2017-18 and 2018-19, respectively. As the issues involved in the captioned appeals are inextricably interlinked and interwoven, therefore, the same are being taken up and disposed off by way of a consolidated order. 2. We shall first take up the appeal filed by the assessee society in ITA No.48/RPR/2021 for assessment year 2016-17 and the said order shall mutatis-mutandis apply to the connected issues involved in the remaining appeals. The assessee society has assailed the impugned order passed by the Pr. CIT-1, Raipur u/s. 263 of the Act dated 30.03.2021 on the following grounds of appeal: "1. On the facts and circumstances of the case, the learned Principal commissioner of Income Tax, Raipur-1 has erred in holding that no enquiry was conducted and no application of mind applied by the learned assessing officer on the issues of claim of deduction under section 80P(2)(d) and verification of expenditure. 2. On the facts and circumstances of the case, the learned Principal Commissioner of Income Tax, Raipur-1 has erred in holding that no enquiry was conducted and no application of mind was done by the learned assessing officer on the issues of claim of....
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....sment record. The Pr. CIT after perusing the assessment record was of a firm conviction that the assessment order passed by the A.O u/s. 143(3), dated 28.12.2018 was erroneous in so far it was prejudicial to the interest of the revenue on multiple issues, which for the sake of convenience are culled out as under: (i) The Pr. CIT observed that a perusal of the record of the assessee society for the subject year revealed that it had earned interest income as under: Interest earned on FDR Rs. 35,89,32,299/- Interest earned on Savings Account Rs. 1,23,00,968/- Interest earned on record from other sources Rs. 65,370/- Interest earned on FFD A/c. Rs. 4,39,52,970/- Interest earned on Group Gravity a/c. Rs. 31,32,657/- Interested earned on group leave encashment and scheme a/c. Rs. 23,40,819/- Interest earned on Federation seed capital (Apex Bank) Rs. 6,02,40,190/- Total Rs. 48,09,65,273/- It was observed by him that the interest income of Rs. 6,02,40,190/- earned by the assessee society on its seed capital was claimed as a deduction u/s. 80P(2)(d) of the Act. It was further observed by him that all other interest income (su....
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....ification." (iii) The Pr. CIT on a perusal of the "balance sheet" of the assessee society, observed that the assessee society was having FDRs with certain banks/cooperative banks. It was observed by him that though the assessee society had claimed deduction of the interest on seed capital u/s. 80P(2)(d) of the Act but had not included the interest income accrued on the balance FDRs in its computation of income for the subject year. Accordingly, the Pr. CIT was of the view that though the interest receipts aggregating to Rs. 2,43,35,41,000/- received by the assessee society from various banks would have formed part of its total income but no details regarding the said issue were called for by the A.O while framing the assessment; AND (iv) The income of Rs. 2,43,35,41,000/- and expenses of Rs. 1,60,35,76,711/-(sic) disclosed in the profit and loss account of the assessee society required further verification. 6. Accordingly, the Pr. CIT based on his aforesaid deliberations was of a firm conviction that the assessment order passed by the A.O was erroneous in so far it was prejudicial to the interest of the revenue. The Pr. CIT issued a "Show Cause Notice" (SCN), d....
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....nd object: In the state of Chhattisgarh around 44% of the area is covered by dense forest. In the forest area there are many forest produce gets grown which are collected by the tribal and villagers residing in such area. It is estimated that approximately fourteen lakhs families are getting their livelihood from collection of the forest produce which are grown in the forest area of Chhattisgarh. These persons do not have management bandwidth to get proper value of forest produce collected by them and in order to get them the monetary benefit of the forest produce collected by them; the State Government initiated a structure of co-operative movement so that entire benefit of the forest produce is passed on the person collecting it from the forest. In earlier regime forest used to be allotted by the State Government, to private Contractors through auction. State Government used to earn auction money from such contractors These contractors were free to collect the forest produce from the jungle allotted to them. This method was not giving the benefit of forest produce to the tribal people/ villagers who were actually collecting such forest produce. On the contrary t....
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....constituted by its members who are local villagers/ tribal's of the area. These members elect their Board of Directors. There after the primary cooperative societies in turn select the director for the District Cooperative Union. Thereafter the District Cooperative Union elects and selects the board of directors of the assessee Federation. Thus so far as the assessee federation is concerned, all its agency related activities are devoted towards the mandate received by the State Government to act for the betterment of villagers and tribal(s). Thus there is a three tier structure as under: 1. Upfront prayer of the Assessee federation : 1. The assessee Federation has its own seed capital and the same is deposited with a Cooperative bank. 2. Interest earned on the seed capital forms part of the income portion of the assessee federation. 3. Under the provisions of section 80P (2) of the Income Tax Act such interest is eligible for deduction and accordingly it was claimed by the assessee federation. 4. The case of the assessee Federation for Assessment year 2016-17 was selected for Complete Scrutiny Assessment vide notice....
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....eous nor it is prejudicial to the interest of the revenue. 1. It is further respectfully submitted that notice under section 263 of income tax act is definitely erroneous and this is exhibited by following factual narration: 1. It is mentioned on the first Para of the notice received (Page 1 of 6): "On examination of your Income Tax records for the above assessment order, I find that the order passed u/s. 143(3) r.w.s 147 on 28.12.2017 of the Income Tax Act, 1961 is erroneous in so far as it is prejudicial to the interest of revenue in the following manner." It can be seen that while sending a notice it is mentioned that earlier Assessment order was passed under Section 143(3) read with section 147. This is factually incorrect. There was no proceeding initiated under section 147 against the assessee and record would reflect this submission is factually correct. 1. In Para 4 of the notice received (page 5 of 6) it is mentioned that: "Hence, there is no application of mind on part of the AO to correctly tax the income of the assessee in the return of income and therefore, the assessment order passed u/s 144 of the Act is erroneous....
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....Kullu Gond etc. After considering the submission of the assessee and income declared in the return of income filed for the year under consideration, the returned income of the assessee is found acceptable. Accordingly, income of the assessee, as discussed above, is assessed at Nil." So far as above interest income is concerned in view of the categorical submission made before the learned assessing officer, during the assessment proceeding itself along with the strength of the supporting documentary evidence i.e. copy of order of the Chhattisgarh State Government dated 23-02-2001, it was explained that only the interest income accruing on seed capital invested by the Federation is the income of the Federation and for all other activities carried out by it although separate accounts are to be maintained by it, though the accounts are in the capacity of Federation being the agency and not for its own. Thus out of the interest income mentioned above in the table, only interest earned on Federation seed capital i.e. Rs. 6,02,40,190/- is income of the assessee. This has been duly noted by the learned assessing officer and appropriate deduction under section 80P(2)(d) has been al....
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....uly assessed. The applicable legally admissible deductions under section 80P(2)(d) has been allowed to the assessee and which does not require any revisiting on the issue. 1. Reply for Para 2.2 (Page 3 of 6): In this para, again a factually incorrect statement has been made that the veracity of payable expenses has not been verified during the original assessment. It can be seen that the case was selected for Complete scrutiny under section 143(2). Thereafter the assessing officer has verified complete books of accounts and records maintained by the assessee. As a result of the complete and full verification of all the liabilities, the assessing officer pointed out query on interest income earned which was replied by the assessee to the satisfaction of the learned assessing officer. Hence the statement that it has not been verified is not factually correct and is not based on any evidence on record. 1. Reply for Para 3 (Page 4 of 6): In this Para it is mentioned that on further analysis of Balance Sheet of the assessee, it is found that the FDR has been received from certain banks other than cooperative then a table has been app....
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....been referred in our case. It is thus clear that such an ambiguous notice is not at all sustainable in law. Our submissions in support of the above facts in the light of various, judicial Pronouncements: The facts as stated above existent in our case are supported by judicial pronouncements in various cases on similar facts and case. The facts and relevant judicial pronouncement are produced below for your honor's kind consideration: 1. It is respectfully submitted that on the points mentioned in the notice u/s 263 an attempt has been made to bring on record that there are two views on the same subject. In this manner a case has been attempted to be made that the order passed by the learned Assessing officer was erroneous and prejudicial. This is not based on facts and circumstance and further more Hon'ble Supreme Court in the case of Commissioner of Income Tax Vs. Max India Ltd. (2007) 213 CTR 0266, (2007) 295 ITR 0282, (2008) 166 TAXMAN 0188 has clearly held that where there are two views possible and ITO has already taken one view with which the Hon'ble CIT does not agrees it cannot be held to be erroneous order or prejudicial to t....
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....ch foundation on record justifying invocation of exercise of revisionary powers that too suo moto. Thus exercise of revisionary powers in the absence of clear foundation power is impermissible. This is also been held in the judgment given by the HIGH COURT OF MADHYA PRADESH in the case of judgment where on similar fan the COMMISSIONER OF INCOME TAX vs. Ramesh Singh. While delivering the judgment honorable High Court had also relied upon various other and circumstances the Division Bench decision of the Bombay High Court in Commissioner of Income Tax Vs. Gabriel India Limited (1993) 203 ITR 108 (Bombay) had held that the interference in the present case with the assessment order was not justified. The said case was also referred in Commissioner of Income Tax Vs. M/s Associate Food Products Pvt. Limited, Jabalpur, which was decided on 21.11.2005 in which the above judgment of the Bombay High Court was followed and it was held that it is clear as Crystal that before exercise of power under section 263 of the Act, two requisites are imperative to be present. In the absence of such foundation exercise of a suo motu power is impermissible. It should not be presumed that initiation of pow....
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....n on the same fact. Please refer to judgment given by Hon'ble High court of Madhya Pradesh in the case of COMMISSIONER OF INCOME TAX vs. JAGDISH KALANI (2006) 74 CCH 0126 MPHC 1. It is respectfully submitted that in our case the view taken by the learned assessing officer is well within the four corners of the law and therefore as was held in BHAGYODAYA FRIENDS URBAN CO-OP BANK LTD. vs. PRINCIPAL COMMISSIONER OFINCOME TAX by Hon'ble ITAT NAGPUR in (2016) 48 CCH 0359 Nag Trib that in such a situation exercise of jurisdiction by CIT was not valid. While giving this decision Hon'ble ITAT relied upon the decision of apex court in the case of CIT vs. Max India Ltd. 295 ITR 282. Similar decision has also been given by ITAT Nagpur in case of HARIHAR HOUSING AGENCY vs. COMMISSIONER OF INCOME TAX (2015) 45 CCH 0541 Nag Trib. 1. It is respectfully submitted that we had given all detailed explanation and requisite information with respect to various issues during the assessment proceedings. These have been duly examined by the learned AO before completing the assessment and the AO has taken up the matter and the order was passed by him. This cannot be regarded as....
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....t of and in the interest of revenue administration. Such a power cannot in any manner be equated to or regarded as approaching any way in appellate jurisdiction or even the ordinary revisional jurisdiction conferred on the Commissioner under section 264. 1. It was decided in Cf. Bidar SahakarKarkhane Ltd. V. State of Karnataka, (1985) 58 STC 65, 67, (Karn): H. Kenche Gowda v. State of Karnataka, (1988) 174 ITR 389, 393(Karn) that revision vis-a-vis income escaping assessment. The revision power under section 263 cannot be exercised in respect of a matter which falls within the power to assess escaped income. The revising authority, in order words, should not trench upon the powers which are expressly reserved to the Assessing Officer under section 147. The Commissioner, in exercise of its revision jurisdiction, should not ignore such specific power. 1. It was decided in Garden Silk Mills Ltd. V. CIT, (1996) 221 ITR 861, 865, 866-67 (Guj) that no power to ignore binding decisions. In passing an order of revision under section 263, the Commissioner is not empowered to ignore the binding decisions rendered by the Supreme * Court or even by the jurisdictional High Cou....
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.... 1. It was decided in CIT v. Barbheta Estate Pvt. Ltd. (2001) 252 ITR 379, 381 (Call). Also see, CIT v. General Magnets Ltd. (2002) 256 ITR 471, 475 (Cal) that the term 'erroneous' can be looked into from the facts and circumstances and the materials which were placed before the Assessing Officer at the time of the assessment. There is no scope under section 263 to reopen an assessment on subsequent event nor any new material [Jai Kumar Kankaria v. CIT, (2001) 251 ITR 707, 710 (Cal]. In that view of the matter, the Tribunal has been held justified in law in holding that the Commissioner was not empowered under section 263 to direct the Assessing Officer not to allow deduction under section 35CCA on the basis of the withdrawal of approval of the payee-society by a subsequence order, which was purported to be given retrospective effect. 1. It was decided in Dawjee Dadabhoy & Co. v. S.P. Jain (1957) 31 ITR 872 (Cal); Add CIT v. Mukur Corporation, (1978) 111 ITR 312 (Guj); CIT v. Gabriel India Ltd., (1993) 203 ITR 108, 115, 116 (Bom); CIT v. Smt. Minalben S. Parikh, (1995] 215 ITR 81, 86-87 (Guj) that prejudicial to the interest of the revenue.- The words "prejud....
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....l requirement, but the order not fulfilling this requirement, cannot be said to be erroneous and pre-judicial to the interests of the Revenue. It is for the Commissioner to point out as to what error was committed by the Assessing Officer in having reached the conclusion that the income of the trust was exempt in its hands and was assessable only in the hands of the beneficiaries. The Commissioner having failed to point out any error, no error can be inferred from the orders of the Assessing Officer for the simple reason that they are bereft of details. If the order is not erroneous, then it cannot be prejudicial to the interests of the Revenue. In the case of the assessee no error has been pointed out in the notice hence the notice is liable to be quashed as there is nothing erroneous and therefore nothing prejudicial to the interests of the revenue. 1. As is evident from the assessment order under consideration, all the requisite information / evidence in support of the return, had been furnished and it was only after satisfying himself that the information furnished, explains the returns of income, that the assessing officer had framed assessment. 1. Thus, the ....
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....fied about their correctness and completeness. Hence since the enquiry contemplated in the notice u/s. 263 having already been instituted and completed by the A.O., before framing assessment under section 143(3) of the Act, the present proceedings u/s 263 of the Act in the light of the above facts and judicial analysis, being invalid and without jurisdiction, needs to be dropped. 1. The A.O. had framed the assessment after satisfying himself with respect to the correctness and genuineness of all the information/evidences obtained from the assessee, as per law. Such a legally completed assessment cannot be interfered with by the CIT u/s 263 as the law does not envisage that the CIT can impose upon the A.O. to make an assessment as the CIT likes. Powers of assessment are vested with the A.O. and not with the CIT who simply holds supervisory powers to ensure that the interests of both the parties is not adversely affected. 1. It is respectfully submitted that it was held in Russell Properties Pr. Ltd. v. Addl. CIT, (1977) 109 ITR 229, 245 (Cal) that in order to exercise the power under section 263(1), there must be material for the Commissioner to consider t....
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....e the order of the Officer, issued a direction for making assessment afresh, the Tribunal was held justified in vacating the revision order. 1. It is respectfully submitted that it was held in CIT v. General Trade Agencies, (1973) Tax LR 1383 (Cal) that where the show cause notice did not fairly indicate the grounds used by the Commissioner in his order under section 263, it was held that the assessee was deprived of fair opportunity to show cause against proposed action. In such a case, the revision order of the Commissioner cannot be sustained. 1. It is respectfully submitted that the Calcutta High Court was held in Bagsu Devi Bafna v. CIT (1967) 63 ITR 333 (Cal), thus laid down the extent and limitations of the rules of natural justice applicable to section 263. 1. It is respectfully submitted that it was held in Hindu ank Karur Ltd. v. Addl. CIT, (1976) 103 ITR 553 (Mad) that the words "erroneous in so far as they are prejudicial to the interests of the revenue" have to be taken together and require to be widely construed. 2. It is respectfully submitted that it was held in Jai Kumar Kankaria v CIT [2001] 251 ITR 707 (Cal.) that the term '....
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....cessary for the Commissioner to state in what manner he considered that the order of the ITO was erroneous and prejudicial to the interests of the revenue and what was the basis for such a conclusion. 1. In the case of KARTHIK FINANCIAL SERVICES LTD. vs. COMMISSIONER OF INCOME TAX (2019) 55 CCH 0170 Mum Trib it was held that when details were made available with AO, who with due application of mind as well as after due examination, accepted assessee's CIT on this account were factually incorrect and working. Consequently, observations made by CIT on this account were factually incorrect and, therefore, same could not form basis of invoking revisional jurisdiction u/s 263. 1. In the case of PRAVARDHAN SEEDS PVT. LTD. vs. ASSISTANT COMMISSIONER OF INCOME TAX (2019) 55 CCH 0086 HydTrib it was held that In terms of s. 263, CIT shall not stop merely on finding that order was erroneous but also had to establish that order of AO was prejudicial to interests of Revenue. 1. In the case of COLORS TEXTILES LIMITED vs. INCOME TAX OFFICER (2018) 54 CCH 0300 Chd Trib it was held that Mere suspicion cannot be the basis for holding that the enquiry conducted by the A....
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....did not find favour with the same. The Pr. CIT observed that the submissions of the assessee society were neither convincing nor satisfactory. He was of the view that as the order passed by the A.O u/s. 143(3) of the Act, dated 28.12.2018 was without application of mind and conducting necessary enquiries, thus, the same was rendered as erroneous in so far it was prejudicial to the interest of the revenue. The Pr. CIT relied upon certain judicial pronouncements wherein the Hon'ble Courts/Judicial Forums had observed that in a case where the assessment was framed by the A.O without carrying out necessary enquiries and application of mind then exercise of jurisdiction by the Commissioner u/s. 263 was justified. The Pr. CIT after referring to the case records and submissions of the assessee society which were furnished both during the course of assessment proceedings and in the course of revisional proceedings before him, observed that the A.O while framing the assessment had not conducted proper enquiries regarding the genuineness of the contentions that were raised by the assessee society. Accordingly, the Pr. CIT based on his aforesaid observations, concluded that the assessment....
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....ed that about fourteen lakhs families (approx.) comprising of tribals and villagers residing in the forest areas are getting their livelihood from collection of the forest produce which are grown in the forest areas of Chhattisgarh. As the aforesaid persons were unable to get proper value for the forest produce collected by them, therefore, the State Government had initiated a structured co-operative movement so that the entire benefit of the forest produce is passed on to the persons collecting it from the forests. As brought to our notice by the Ld. AR in the earlier regime forests used to be allotted by the State Government to private contractors through auction. As the contractors were free to collect the forest produce from the jungles allotted to them, the benefit of forest produce would not fully pass on to the tribal people/ villagers who were actually collecting the same. Considering the fact that the tribals/villagers were not being properly compensated for the value of the forest produce by the private contractors the assessee society was brought into existence under the provisions of Chhattisgarh Sahkari Society Adhiniyam, 1960 read a/w. Chhattisgarh Sahkari Society Rul....
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....ope of his jurisdiction by taking recourse to proceedings u/s. 263 of the Act. Our attention was drawn by the Ld. AR to the "computation of income" of the assessee society for the subject year. The Ld. AR submitted that though the assessee society was in receipt of interest on deposits with a co-operative bank of Rs. 6.02 crore (approx.) but had restricted its claim for deduction u/s. 80P(2)(d) of the Act to the extent of its total taxable income, i.e. Rs. 5.93 crore (approx.). Carrying his contention further, the Ld. AR submitted that the assessee society in its agency "profit and loss account" for the subject year, after considering the gross surplus/profit brought forward from the trading account of Rs. 132.49 crore (approx.) and indirect income of Rs. 43.01 crore (approx.) [including interest income of Rs. 41.51 crore (approx.)] had after considering the expenses incurred in respect of its aforesaid activities as an agent was left with a net surplus/profit of Rs. 167.91 crore (approx.) which was to be distributed/payable to the members of the society in the ratio 80 : 15 : 5 as it was the income of the primary co-operative societies. The Ld. AR explaining the basis for distribu....
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....ia, submitted before the A.O that the amount of Rs. 685.62 crore (approx.) shown on the liability side of the balance sheet as "payable to the societies (C.G.)" was a year-wise accumulation payable to 901 village societies which were the beneficiaries of the forest produce. 16. The Ld. AR based on his aforesaid contention tried to impress upon us that as the A.O while framing the assessment had queried on the various facets of the issues which, after necessary deliberations and considering the reply of the assessee were accepted by him, therefore, the Pr. CIT in the garb of proceedings u/s. 263 of the Act had grossly erred in traversing beyond the scope of his jurisdiction for seeking substitution of his view on the said issues as against that arrived at by the A.O. Also, the Ld. AR submitted that as the A.O had taken a conscious view on the multi-facet issues which were debatable in nature while framing the assessment, therefore, the Pr. CIT could not have stepped in and dislodged such plausible view in exercise of powers vested with him u/s. 263 of the Act. 17. The Ld. AR had further assailed the validity of the jurisdiction assumed by the Pr. CIT u/s. 263 of the Act for th....
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....litates against the aforesaid pre-condition for valid assumption of jurisdiction. The Ld. AR submitted that as the Pr. CIT had failed to satisfy the statutory pre-condition for valid assumption of jurisdiction u/s. 263 of the Act and had merely acted upon the report/reasons provided by the A.O, therefore, the jurisdiction so assumed by him for initiating proceedings u/s. 263 of the Act suffered from a fundamental defect, which, thus, rendered the entire proceedings and the consequential order so passed by him as void-ab-initio. The Ld. AR to buttress his aforesaid claim had relied on the order of the ITAT, Jaipur in the case of Shri Dharmendra Kumar Bansal Vs. CIT (2015) 152 ITD 406 (Jaipur). It was submitted by the Ld. AR that the Tribunal in its aforesaid order had held that the Commissioner before taking any action u/s. 263 of the Act, must record his satisfaction and issuance of notice u/s. 263 of the Act on the basis of a proposal made by the ITO would be void ab initio. Also, the Ld. AR had drawn support from the order of the ITAT, Ahmedabad in the case of M/s. Shantai Exim Ltd. Vs. CIT (2016) 178 TTJ 451 (Ahd.). 20. The Ld. AR has further assailed the order passed by the ....
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.....Y.2014-15 had disclosed its income comprising of, viz. (i) agency's commission: Re.1/- (Rupee one) AND (ii) interest on seed capital lying as bank deposit which was claimed as deduction u/s. 80P(2)(d) of the Act. The Ld. AR submitted that the assessee society in its aforesaid returns for the preceding years had alike the year under consideration disclosed interest income/surplus as payable to the primary co-operative societies in the ratio of 80:15:5. The Ld. AR submitted that the returns of income of the assessee society for the A.Ys. 2012-13 to 2014-15 were duly scrutinized and accepted by the A.O's vide their respective orders u/s. 143(3) of the Act. The Ld. AR in order to fortify his aforesaid contention had drawn our attention to the copies of the returns of income, computation of income and financial statements of the assessee society for A.Y.2012-13 to A.Y.2014-15 a/w. copies of the respective assessment orders wherein the income disclosed by the assessee society was accepted by the then A.O's u/s. 143(3) of the Act, Page 213 to 260 of APB. The A.R had specifically drawn our attention to the assessment orders passed u/s. 143(3) of the Act for the respective year....
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.... exhaustive submissions of the assessee society had by way of a non-speaking order rejected the same and set-aside the assessment order in the garb of the powers vested with him u/s. 263 of the Act. The Ld. AR to fortify his aforesaid contention had taken us through the written submissions qua the various aspects/issues which were raised by the Pr. CIT vide SCN dated 11.03.2021, Page 01 to 18 of APB. 23. Per contra, the Ld. Departmental Representative (for short 'DR') relied on the orders of the lower authorities. The Ld. DR had controverted the contentions that were advanced by the assessee's counsel. It was submitted by the Ld. DR that the A.O while framing the assessment had without carrying out any verification grossly erred in summarily accepting the claim of the assessee for deduction u/s. 80P(2)(d) of the Act. Apropos the claim of the assessee's counsel that the Pr. CIT had wrongly assumed jurisdiction without calling for and examining the records of the assessee society, and had merely endorsed the reasons as were recorded by the ACIT-1(1), Raipur for revising the order u/s. 263 of the Act, i.e. without any application of mind to the material facts emanat....
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.... but thereafter, had vide his order passed u/s. 263 of the Act, dated 30.03.2021 revised the same only on two-aspects, viz. (i) verification of the assessee's claim for deduction u/s. 80P(2)(d) of the Act of the interest income received from banks on FDRs, FFD and SB interest etc.; and (ii) to verify the assessee's claim for expenses. It was submitted by the Ld. DR that as the Pr. CIT after specifically confronting the assessee society vide SCN dated 11.03.2021, on the aforesaid issues, had considered its reply (as culled out in the body of the order passed u/s. 263 of the Act) and had observed that the A.O had failed to conduct proper inquiries regarding the genuineness of the contentions that were advanced by the assessee on the aforesaid issues, viz. (i) assessee's claim for deduction u/s. 80P(2)(d) of the Act of the interest income received from banks on FDRs, FFD and SB interest etc., and (ii) assessee's claim for expenses; therefore, the order so passed by him was erroneous in so far it was prejudicial to the interest of the revenue in view of "Explanation 2(a)" to Section 263 of the Act. The Ld. DR submitted that the Pr. CIT after considering the reply of the....
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.... viz. (i) non- verification of the claim of the assessee society for deduction of the interest receipts from the banks on FDRs, FFD and Savings bank interests etc. u/s. 80P(2)(d) of the Act; and (ii) non-verification of the assessee's claim of expenditure. 30. We, thus, considering the aforesaid directions given by the Pr. CIT-1, Raipur vide his order passed u/s. 263 of the Act dated 30.03.2021 confine our adjudication to the aforesaid two issues, on which, the order passed by the A.O u/s. 143(3) of the Act dated 28.12.2018 had been set-aside for fresh adjudication by the Pr. CIT. (A) RE : CLAIM FOR DEDUCTION U/s. 80P(2)(d) OF THE ACT : 31. On a perusal of the computation of income of the assessee society for the subject year, i.e. A.Y.2016-17, Page 122-123 of APB, it transpires that it had raised a claim for deduction of the interest on its deposits (seed capital) with a cooperative bank amounting to Rs. 6,02,40,190/- u/s. 80P of the Act. 32. Admittedly, as observed by the Pr.CIT the interest of Rs. 6,02,40,190/- (supra) was earned by the assessee society during the year on its seed capital. On further perusal of the record, it transpires that the assessee society ....
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.... CIT. Before proceeding any further, we may herein reproduce the relevant extract of the aforesaid statutory provision, viz. Sec. 80P(2)(d), as the same would have a strong bearing on the adjudication of the issue before us. "80P(2)(d)(1). Where in the case of an assessee being a co-operative society, the gross total income includes any income referred to in sub- section (2), there shall be deducted, in accordance with and subject to the provisions of this section, the sums specified in sub-section (2), in computing the total income of the assessee. (2). The sums referred to in sub-section (1) shall be the following, namely:- (a)............................................................................................ (b)............................................................................................ (c)............................................................................................ (d) in respect of any income by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society, the whole of such income;" On a perusal of Sec. 80P(2)(d), i....
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....vert to the judicial pronouncements that have been relied upon by the ld. A.R. We find that the issue that a co-operative society would be entitled for claim of deduction under Sec. 80P(2)(d) on the interest income derived from its investments held with a co-operative bank is covered in favour of the assessee in the following cases: (i) Land and Cooperative Housing Society Ltd. Vs. ITO (2017) 46 CCH 52 (Mum) (ii) M/s C. Green Cooperative Housing and Society Ltd. Vs. ITO-21(3)(2), Mumbai (ITA No. 1343/Mum/2017, dated 31.03.2017 (iii) Marvwanjee Cama Park Cooperative Housing Society Ltd. Vs. ITO- Range-20(2)(2), Mumbai (ITA No. 6139/Mum/2014, dated 27.09.2017. (iv). Kaliandas Udyog Bhavan Pemises Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai We further find that the Hon'ble High Court of Karnataka in the case of Pr. Commissioner of Income Tax and Anr. Vs. Totagars Cooperative Sale Society (2017) 392 ITR 74 (Karn) and Hon'ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), had held, that the interest income earned by the assessee on its investments with a co-operative bank would be eligible for....
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....TR 74 (Karn) and Hon'ble High Court of Gujarat in the case of State Bank Of India Vs. CIT (2016) 389 ITR 578 (Guj), wherein it was observed that the interest income earned by a cooperative society on its investments held with a co-operative bank would be eligible for claim of deduction under Sec.80P(2)(d) of the Act. 9. Be that as it may, in our considered view, as the A.O while framing the assessment had taken a possible view, and therein concluded that the assessee would be entitled for claim of deduction under Sec. 80P(2)(d) on the interest income earned on its investments/deposits with co-operative banks, therefore, the Pr. CIT was in error in exercising his revisional jurisdiction u/s 263 for dislodging the same. In fact, as observed by us hereinabove, the aforesaid view taken by the A.O at the time of framing of the assessment was clearly supported by the order of the jurisdictional Tribunal in the case of Land and Cooperative Housing Society Ltd. Vs. ITO (2017) 46 CCH 52 (Mum). Accordingly, finding no justification on the part of the Pr. CIT, who in exercise of his powers under Sec. 263, had dislodged the view that was taken by the A.O as regards the eligibility of ....
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....h the written submissions filed by the assessee society in reply to the aforesaid query letters. 36. We have thoughtfully considered the aforesaid claim of the assessee society and are unable to persuade ourselves to subscribe to the same. As observed by us hereinabove, though the Pr. CIT vide SCN dated 11.03.2021 had initially sought to revise the assessment order passed by the A.O u/s. 143(3) of the Act, dated 21.12.2018 on multiple issues but had thereafter revised the order only on two issues, viz. (i) verification of the assessee's claim for deduction u/s. 80P(2)(d) of the Act of interest income received from banks on FDRs, FFD and SB account interest etc., and (ii) to verify the assessee's claim for expenditure. Although, it is the claim of the Ld. AR that the assessee society had filed replies regarding the subject issues in the course of the proceedings before the A.O but we find the same to be factually incorrect. 37. On a perusal of the replies in the backdrop of the records available before us, it transpires that nothing is discernible therefrom which would reveal that the seed money of the assessee was lying in the form of deposits with a co-operative bank....
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....n the course of the assessment proceedings, and also the replies filed by the assessee in compliance thereto. On perusal of the reply dated 24.12.2018, it transpires that the assessee society on the issue of the aforesaid amount of Rs. 167.91 crore (approx.) had stated that the same was transferred to the primary co-operative societies on account of profit from sale of tendu leaves and interest earned on the time/fixed deposits on the idle funds of the society in order to avoid any revenue loss. For the sake of clarity, the reply filed by the assessee society is culled out as under: "e. That on the perusal of submitted agency profit and loss account this may please be observed that total amount transferred to the Society is Rs. 167,91,37,711.77 which is on account of Tendu leaves and interest on surplus distributable fund to them kept with bank against Time/Fixed Deposit to earn interest so that no revenue loss also could be suffered by the societies till the payment is made to them as the fund belongs to them only." Although it was clarified by the assessee society that as the aforesaid amount was the surplus on account of business of trading of tendu leaves along with....
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....ribution of "net profit" of tendu leaf business in the aforesaid ratio, i.e. 80:15:5. It was submitted by the Ld. AR that the allocation of the surplus from the trading of tendu leaves and interest on bank deposits of the primary co- operative societies amongst the various heads was based on the order of the Government of Chhattisgarh, Forest Environment and Cultural Department. As the Pr. CIT in his order u/s. 263 of the Act dated 30.03.2021, had observed that "payable expenses" of Rs. 167.91 crore (supra) needs further verification, therefore, the Ld. AR was specifically queried as to on what basis the aforesaid figure was arrived at. It was submitted by the Ld. AR that the amount of Rs. 167.91 crore (supra) was the net of expenses of the gross receipts of trading of tendu leaves and interest income on the bank accounts/deposits of the primary co-operative societies and did not pertain to the assessee society. We find that neither any reply regarding the basis for arriving at the amount of Rs. 167.91 crore (supra) allocated to the co-operative societies or that regarding the expenses claimed in the agency's profit and loss account of the assessee society which had scaled down....
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....ything contained in sub-section (1), where any income in respect of which the person mentioned in clause (iv) of sub- section (1) of section 160 is liable as representative assessee consists of, or includes, profits and gains of business, tax shall be charged on the whole of the income in respect of which such person is so liable at the maximum marginal rate : Provided that the provisions of this sub-section shall not apply where such profits and gains are receivable under a trust declared by any person by will exclusively for the benefit of any relative dependent on him for support and maintenance, and such trust is the only trust so declared by him. (2) Where any person is, in respect of any income, assessable under this Chapter in the capacity of a representative assessee, he shall not, in respect of that income, be assessed under any other provision of this Act." (emphasis supplied by us) Alternatively, the assessee society had though vehemently claimed that the amounts of Rs. 167.91 crore (supra) belonged to the 901 primary co-operative societies but had neither produced before the A.O or the Pr. CIT or before us any material which would conclusiv....
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.... facts of the case by seeking substitution of his view as against that arrived at by the A.O. 42. As in the present case before us, the A.O while framing of the assessment had not queried on the material aspects pertaining to the both the issues, on which, the Pr. CIT had set-aside his order u/s. 263 of the Act, viz. (i) non-verification of satisfaction of the requisite conditions rendering the assessee eligible to claim deduction on interest on bank deposits (seed money) u/s. 80P(2)(d) of the Act; and (ii) non-verification of the claim of expenditure in the agency's profit and loss account of the assessee society, therefore, the judicial pronouncements that had been relied upon by the Ld. AR to impress upon us that where the A.O had while framing the assessment arrived at a plausible view on the issue, the same cannot be substituted in the garb of powers vested with the CIT u/s. 263 of the Act, being distinguishable on facts would by no means assist the case of the present assessee society before us. RE : ABSENCE OF CALLING FOR AND EXAMING OF THE RECORDS BY THE PR. CIT:- 43. We shall now advert to the Ld. AR's contention that the Pr. CIT had grossly erred in law a....
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....ts an obligation on the CIT to call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify. At the threshold, we may herein observe that though it is the claim of the Ld. AR that the Pr. CIT had not called for the assessment record and examined the same, i.e. failed to discharge an obligation which was statutorily required to be satisfied on his part, we are unable to concur with the same. On a perusal of the SCN, dated 11.03.2021 issued by the Pr. CIT u/s. 263 of the Act, we find that he had clearly stated that the notice was being issued after examining the income tax records for the subject year. For the sake of clarity, the relevant extract of the SCN, dated 11.03.2021, Page 7 to 12 of APB is culled out as under: (relevant extract) "On examination of your income tax records for the above assessment year, I find th....
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....to the specific reference of examination of the income tax records of the assessee society by the Pr. CIT in the SCN dated 11.03.2021, and also, similar reference of perusal of the assessment records, financial statements etc. in the body of his order reveals beyond doubt that the case records of the assessee society were called for and examined prior to assumption of jurisdiction by the Pr. CIT u/s. 263 of the Act. In our considered view once the Pr. CIT in the SCN, dated 11.03.2021 had observed that he had examined the records, then it cannot be presumed on the mere say of the assessee that he had without examining the assessment records and application of mind to the same had assumed jurisdiction and issued "show cause" notice to the assessee u/s. 263 of the Act. Our aforesaid view is supported by an analogy that can safely be drawn from a recent order of the Hon'ble High Court of Chhattisgarh in the case of Hitesh Golecha Vs. ACIT, Central Circle-1, Raipur, Tax case Nos. 76 & 79 of 2024, dated 10.04.2024. The Hon'ble High Court in its order had observed as under: "5. The order of the Assessing officer of approval (Annexure - 4) would reflect that Joint Commissi....
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....Ld. AR on a conjoint perusal of the SCN dated 11.03.2021 r.w. reasons recorded by the ACIT-1(1), Raipur at the first blush appeared to be very convincing but a careful perusal of the records revealed a different factual position. Ostensibly, the Pr. CIT after perusing the information provided by the ACIT-1(1), Raipur had incorporated the same in the SCN dated 11.03.2021 issued by him u/s. 263 of the Act. However, we are unable to concur with the Ld. AR that the Pr. CIT had merely acted upon bald observations of the ACIT-1(1), Raipur and had failed to independently apply his mind prior to assuming jurisdiction u/s. 263 of the Act. We, say so, for the reason that though the Pr. CIT was convinced with the material infirmities and lapses emanating from the order passed by the A.O u/s. 143(3) of the Act dated 28.12.2018 as was shared with him by the ACIT-1(1), Raipur, but thereafter, he had duly applied his mind for arriving at a prima facie view that the assessment order so passed was erroneous and prejudicial to the interest of the revenue, and based on his said conviction, had called upon the assessee society to explain as to why the same may not be revised u/s. 263 of the Act. 48....
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....3 of the Act. We, thus, in terms of our aforesaid observations, are unable to concur with the Ld. AR who had alleged that the Pr. CIT had merely acted upon the borrowed observations of the ACIT-1(1), Raipur and in a mechanical manner without any application of mind to the material before him assumed jurisdiction u/s. 263 of the Act. 49. Also, we are unable to concur with the Ld. AR that the Pr. CIT in exercise of jurisdiction u/s. 263 of the Act cannot act upon the information or material provided by his subordinate authorities. As observed by us hereinabove, Section 263 of the Act contemplates that the Pr. CIT for assuming jurisdiction is statutorily required to call for and examine the record of any proceeding under this Act, and if he considers that any order passed by the A.O. is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify. Although, the exercise of revisional jurisdiction by the Pr. CIT pre-supposes as a sine-qua-non application of mind on his ....
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....nt material or information before the CIT. Our aforesaid view is further supported by the order of the ITAT, Kolkata in the case of Karabi Deals (P) Ltd. (2022) 144 taxmann.com. 174 (Kolkata). The Tribunal after relying on the judgment of the Hon'ble High Court of Delhi in the case of ITO Vs. D.G Housing Finance Co. Ltd. (2012) 343 ITR 329 (Delhi) had rejected the claim of the assessee that the Pr. CIT had wrongly assumed jurisdiction u/s. 263 of the Act for the reason that he had acted on the proposal of the A.O and initiated proceedings u/s. 263 of the Act. It was observed by the Tribunal that the information/proposal of the A.O would be nothing more than a "stimuli" for the Pr. CIT which could be either an internal or external source. It was further observed by the Tribunal that the proposal of the A.O would only be suggestive in nature and what was important was application of mind by the Pr. CIT on the records of the case for valid assumption of jurisdiction u/s. 263 of the Act. Accordingly, it was observed by the Tribunal that as the Pr. CIT based on the proposal received from the A.O, had after examining the assessment records and applying his mind embarked upon a journe....
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....of Delhi (i) CIT Vs. Aunaben Sumankumar (2022) 177 CTR 470, High Cour of Gujrat (j) CIT Vs. Gabriel India Ltd. (1993) 203 ITR 108, High Court of Bombay (k) CIT Vs. Amit Corporation (2012) 81 CCH 69, High Court of Gujrat. 53. As observed by us hereinabove, the Ld. AR had submitted that alike the subject year, the assessee society in its return of income for the preceding years, i.e. A.Y.2009-10 to A.Y.2014-15 had returned its income comprising of, viz. (i) agency commission : Re.1/- (Rupee one); and (ii) intertest on its seed capital lying as bank deposits which was claimed as deduction u/s. 80P(2)(d) of the Act. The Ld. AR submitted that as the assessee's returned income had been accepted by the department in the preceding years, therefore, there was no justification for the Pr. CIT to have adopted an inconsistent view during the subject year specifically when the fact situation remained the same. Also, the Ld. AR had submitted that the assessee society had alike the year under consideration disclosed interest income/surplus as payable to the primary co-operative societies in the ratio 80 : 15 : 5 which was consistently accepted by the department s....
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....d while framing assessments for the said years. 55. Be that as it may, in our view all that is required for the Pr. CIT to exercise the jurisdiction vested with him u/s. 263 of the Act is a cumulative satisfaction of the conditions therein contemplated, i.e. if he considers that any order passed by the Assessing Officer is erroneous in so far it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, revise the order in exercise of powers vested with him under the said statutory provision. As nothing is provided in Section 263 of the Act, which jeopardizes the exercise of revisional jurisdiction by the Pr. CIT on the ground that a similar mistake in the preceding year had not been set-right and was allowed to perpetuate, therefore, we find no substance in the Ld. AR's contention who based on the same had tried to circumscribe the scope of jurisdiction of the Pr. CIT u/s. 263 of the Act. Also, we cannot loose sight of the fact that as every assessment year is an independent year and the principle of res-judicata is not applicable to taxing statute....
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.... 263 of the Act to the extent the same would be relevant for adjudicating the aforesaid claim of the assessee, as under: (relevant extract) "263. (1) The Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify.....including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment.", (emphasis supplied by us) Admittedly, the Pr. CIT as per the mandate of Section 263(1) of the Act before holding the order passed by the A.O as erroneous and prejudicial to the interest of the revenue remains under a statutory obligation to "make" or "cause to be made" such inquiry as he deems necessary, and therein pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the ass....
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....ed before both during the course of assessment proceeding and revisional proceedings, was of a firm conviction that the A.O had not conducted proper inquiries regarding the genuineness of the contentions made by the assessee society on both the subject issues, viz. (i) entitlement of the assessee society for claiming deduction u/s. 80P(2)(d) of the Act of the interest on deposits of seed capital stated to have made with co-operative bank/banks; and (ii) verification of the assessee's claim of expenditure. Accordingly, the Pr. CIT after due application of mind and considering the fact that the assessee society had neither provided the requisite details that were required to substantiate its claim for deduction u/s. 80P(2)(d) of the Act and the expenditure, both in the course of the assessment proceedings as well as in the proceedings before him, therefore, had taken a conscious view that in absence of any such details having been filed before him despite specific directions in the course of the revisional proceedings, the matter was required to be remanded back to the file of the A.O for fresh adjudication of the said issues after conducting necessary inquiries and affording an ....
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....e assessee society was being held by him as erroneous and prejudicial to the interest of the revenue. The Ld. AR in support of his contention that the Pr. CIT was statutorily obligated to have applied his mind after examining the records and arrive at a satisfaction that the order so passed by the A.O was erroneous in so far it was prejudicial to the interest of the revenue had drawn support from the following judicial pronouncements: (a) Dharmendra Kumar Bansal Vs. CIT 101 DTR 377 (JP) (b) Shantai Exim Ltd. Vs. CIT 136 DTR 313 ( Ahd.) (c) Alfa Laval Lund AB Vs. CIT (International Taxation), 210 DTR 313 (Pune) (d) Span Overseas Ltd. Vs. CIT, ITA No.1223/PN/2013 dated 21.12.2015 (e) Sh. Raghuvir Singh Vs. PCIT, ITA No.1132/Del/2022 dated 10.11.2023 (f) Sh. Sanjay Kumar and Sh. Dariyav Singh Vs. Pr. CIT, ITA No.2187 & 2029/Del/2018 dated 28.06.2023. 62. We have thoughtfully considered the aforesaid claim of the assessee in the backdrop of the orders of the lower authorities and the material available on record. Although, it is the claim of the Ld. AR that the Pr. CIT had passed the order u/s. 263 of the Act dated 30.03.2021 wit....
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....ne can comprehend that in a case where the details as were called for by the revisional authority were though fully made available but the latter had without applying his mind to the same had held the order passed by the A.O as erroneous and prejudicial to the interest of the revenue that the assessee would be justified in carrying a grievance that without dislodging the authenticity of his claim and considering the supporting material the revisional authority had without application of mind most arbitrarily held the order as erroneous and prejudicial to the interest of the revenue u/s. 263 of the Act. However, it is incomprehensible that while for the assessee society before us had adopted an evasive approach and failed to come forth with the requisite details not only in the course of the assessment proceedings, but also failed to provide the same despite specific directions by the revisional authority, thereafter, is carrying a grievance that the Pr. CIT had failed to apply his mind to the issues and mechanically revised the order passed by the A.O. 63. Apropos the contention of the Ld. AR that as the Pr. CIT had merely copied the reasons recorded by the ACIT-1(1), Raipur for....
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....1 for A.Y.2016-17 is dismissed in terms of our aforesaid observations. ITA No. 47/RPR/2021, ITA No. 49/RPR/2021 & ITA No.152/RPR/2023 A.Ys.2015-16, 2017-18 & 2018-19 67. As the facts and the issues involved in the captioned appeals remains the same as were there before us in the assessee's appeal in ITA No.48/RPR/2021 for A.Y.2016-17, therefore, the view therein taken shall mutatis-mutandis apply for the purpose of disposing off the captioned appeals i.e. ITA No.47/RPR/2021 for A.Y.2015-16, ITA No.49/RPR/2021 for A.Y.2017-18 and ITA No.152/RPR/2023 for A.Y.2018-19. In these cases also, we, finding no infirmity in the view taken by the Pr. CIT who in the totality of the facts involved in the cases before him, had vide his respective orders u/s. 263 of the Act rightly set-aside the assessment order(s) passed by the A.O's u/s. 143(3) of the Act dated 20.12.2017, 23.12.2019 and 27.02.2021 with a direction to re-adjudicate the subject issues after affording a reasonable opportunity of being heard to the assessee society, uphold the same. 68. In the result, appeals of the assessee in ITA No.47/RPR/2021 for A.Y.2015-16, ITA No.49/RPR/2021 for A.Y.2017-18 and ITA No.152/RPR/20....
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....tal signature may be taken as date of document CENTRAL REVENUE BUILDING, RAID2, RAI03, RAI04, RAIPUR, Chhattisgarh, 492001 Email: [email protected]. Document identification No. Document 2 passed on 28.12.2018 assessing the total income at Rs. Nil. 1. On subsequent perusal of records of the assessee for the F.Y. 2014-15, it is found that the assessee had earned interest incomes as: Interest earned on FDR Rs.35,89,32,299/- Interest earned on Saving Account Rs.1,23,00,968/ Interest earned on Record from Other Source Rs.65,370/- Interest earned on FFD A/c. Rs.4,39,52,970/- Interest earned on Group Gravity a/c. Rs.31,32,657/ Interest earned on Group leave encashment and Scheme A/C. Interest earned on Federation seed capital Rs.23,40,819/- Rs. 6,02,40,190/- 2.1 In this case, the assessee has claimed a deduction u/s 80P(2)(d) of Rs. 6,02,40,190/-., which is the interest earned from the cooperative bank. The income earned from banks other than cooperative banks must have been offered as income from other sources. In this case, the income from interest income has been calculated in such a manner that....
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....6/-, to revolving fund of Rs.7,53,72,338/-. The veracity of these payable expenses were not verified during the time of original assessment, whether, these were duly paid in the subsequent years or not. Similarly, the reason of recurrence of these payable expenses was also not enquired into. Document 4 3. Upon perusal and further analysis of the Balance sheet of the assessee it has been found that the FDR has been received from certain banks other than cooperative banks too as described below: FDR A/c. (Allahabad Bank) FDR A/c. (Apex Bank) FDR A/c. (Axis Bank) FDR A/c. (Bank of Baroda) Rs.0/- Rs.67,44,47,382/- Rs.0,/- Rs. 0/- FDR A/c. (C.G. Rajya Gramin Bank) Rs. 2,61,50,00,000/- FDR A/c. (Development Credit Bank) INCOME TAX DEPARTM FDR A/C. (ICICI Bank) FDR A/c. (South Indian Bank) FDR A/c. (State Bank of India) FDR A/c. (UCO Bank) Flexible Fix Deposit (B.O.B) Flexible Fix Deposit (SBI-5823) FDR A/c. (Apex Bank) Rs. 50,00,00,000/- Rs.1,50,00,000/- Rs. 1,50,00,00,000/- Rs.16,32,00,000/- Rs. 0/- Rs.15,75,000/- Rs. 66,000/- Rs.1,44,00,00,000/- Document 5 FDR A/c. (Central B....
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.... the office of PCIT-1, Central Revenue Building, Civil Lines, Raipur. Page 6 of 6 AMRENDRA KUMAR PCIT, Raipur-1 (In case the document is digitally signed please refer Digital Signature at the bottom of the page) Certified True Copy This document is digitally signed Signer: AMRENDRA AR Date: Monday, March 2021 204 Location: BHOPAL Document 7 CH RAJYA LAGHU VANOPAJ (TRADING AND DEVELOPMENT) VYPAR AND VIKAS SAHKARI SANGH MARYADIT (TOP SOCIETY) ↑ JILA VANOPAJ SAHKARI SANGH MARYADIT (DISTRICT LEVEL -31 SOCIETIES) PRATHMIK VANOPAJ SAHKARI SAMITI MARYADIT (PRATHMIK -901 SOCIETIES) Document 8 CH RAJYA LAGHU VANOPAJ (TRADING AND DEVELOPMENT) VYPAR AND VIKAS SAHKARI SANGH MARYADIT (TOP SOCIETY) ↑ JILA VANOPAJ SAHKARI SANGH MARYADIT (DISTRICT LEVEL -31 SOCIETIES) ↑ PRATHMIK VANOPAJ SAHKARI SAMITI MARYADIT (PRATHMIK -901 SOCIETIES) Document 9 छतà¥à¤¤à¥€à¤¸à¤—ॠशासन वन विà¤à¤¾à¤— दाऊ कलà¥à¤¯à¤¾à¤£ सिंह à¤à¤µà¤¨, मंतà¥....
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.... 15 पà¥à¤°à¤¤à¤¿à¤¶à¤¤ पाश संगà¥à¤°à¤¾à¤¹à¤•à¥‹ समितियों को अंराषà¥à¤Ÿà¥à¤°à¥€à¤¯à¤•à¥ƒà¤¤ लघॠवनोपज के वà¥à¤¯à¤¾à¤ªà¤¾à¤° हेतॠकराई जाये 1 यह राशि समितियों को अंराषà¥à¤Ÿà¥à¤°à¥€à¤¯à¤•à¥ƒà¤¤ लघॠवनोपज के à¤à¤µà¤‚ विक à¤à¤‚डारण तथा पà¥à¤°à¤¸à¤‚सà¥à¤•à¤°à¤£ हेतॠउपलबà¥à¤§ कराई जाà¤à¤—ी। समितियों दà¥à¤µà¤¾à¤°à¤¾ यह कारà¥à¤¯ लघॠवनोà¤....