2025 (6) TMI 1913

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....vocate For The Respondent : Smt.Leena Lal, Sr.AR ORDER PER PRAKASH CHAND YADAV, JM : The present appeal of the assessee is arising from the order of the National Faceless Appeal Centre / learned Commissioner of Income-tax (Appeals) ["CIT(A)" for short] dated 04.03.2024, having DIN & Order No.ITBA/NFAC/S/250/2023-24/1061939408(1) and relates to the assessment year 2020- 2021. 2. Brie....

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...., the assessee filed an appeal before the ld.CIT(A) and assailed that the view of the AO is not tenable. However, the ld.CIT(A) partly allowed the appeal of the assessee and sustained the addition of Rs. 30,79,758/-. 4. Aggrieved with the order of the CIT(A), the assessee has come up in appeal before us and argued that the assessee is entitled for the deduction u/s.80P(2)(d) with respect of the....

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....''We also find force in the submission of the learned Senior counsel, distinguishing the decision of the Supreme Court in M/s. The Totgars' Cooperative Sale Society Limited (supra), on the ground that the Court in that case had found that the Society concerned had appropriated amounts forming part of surplus receipts which were due to its members, and invested the same to earn interest during ....

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....perative Rural Bank Ltd. (supra) and Tumkur Merchants Souharda Credit Cooperative Limited (supra)." 8. We also rely upon the order of the Tribunal in ITA No.496/Coch/2024 (order dated 10.12.2024) in the case of Thrissur District Electricity Board Employees Co-op Society Limited, wherein the same combination of us have held the verdict of Sahyadri Co-operative Credit Society Ltd. (supra). ....