2022 (4) TMI 1649

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....t(s) No. 1 ORAL ORDER PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA 1 We have heard Ms. Kalpana Raval, the learned Senior Standing Counsel appearing for the Revenue. 2 This Tax Appeal at the instance of the Revenue is admitted on the following substantial questions law: "[i] Whether on the facts and circumstances of the case and in law, the Hon'ble Tribunal had erred in holding t....

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.... [iii] Whether on facts and circumstances of the case and in law, the Hon'ble Tribunal had erred in quashing the revision proceedings u/s 263 of the Income Tax Act by overlooking the fact that the Hon'ble High Court of Karnataka in the case of Totgars Cooperative Sale Society (2017) 395 ITR, has held that the intention of legislature is clear that cooperative banks are not specie of genus ....