2025 (2) TMI 1209

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....with Section 147 and 144 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') vide his orders of different dates i.e., 20th December, 2019 and 21st December, 2019. 3. The penalties under dispute were levied by the Assessing Officer of NFAC, Delhi for both the assessment years i.e., for assessment year 2012-13 under Section 271(1)(c) of the Act and for assessment year 2017-18 under Section 271A of the Act. 4. At the outset, learned Counsel for the assessee stated that the facts and circumstances in both the appeals are exactly identical and issue of levy of penalty under Section 271(1)(c) in assessment year 2012-13 and under Section 271A for under reporting of income is also identical, hence, he argued ITA No.4428/Del....

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....ssessee preferred appeal before the learned CIT(A). The learned CIT(A) also confirmed the action of the Assessing Officer. Aggrieved, assessee is in appeal before the Tribunal. 6. I have heard rival contentions and perused the material placed on record. I noted from the argument of the learned Counsel for the assessee that the assessee being cooperative and thrift society limited and its income earned from fixed deposits made with banks including cooperative banks is exempt under Section 80P(2)(i) notwithstanding it was also giving loans to its members not relating to agriculture. The learned Counsel also relied on the decision of Hon'ble Supreme Court in the case of Kerala State Co-operative Agricultural & Rural Development Bank Ltd. ....