2023 (4) TMI 1447

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....n behalf of the assessee Shri Vijay Kumar, Addl. CIT, appeared on behalf of the Revenue ORDER Per Dr. Manish Borad, Accountant Member:- This appeal at the instance of assessee for assessment year 2015-16 is directed against the order of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 18.11.2022, which is arising out of the order under secti....

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....ced before us. We notice that the assessee is a Cooperative Society engaged in the business of providing credit facilities to its members. Nil income declared in the return filed for A.Y. 2015-16 on 30.09.2015. During the course of assessment proceedings, assessee carried out the matter after the case being selected for scrutiny under CASS followed by serving of notices under sections 143(2) and 1....

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....ve Society shall create a bad debt fund by transferring of not less than fifteen per cent, of its net profit in a Cooperative year and shall utilize it in any business if it has no outside liability in the form of bad debt certified by the audit officer or in such other manner as may be prescribed. 82. Every Cooperative Society shall transfer, in every cooperative year, not less than ten ....

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....ooperative Society in such manner as may be prescribed. 7. Now the claim of the assessee is that it apportion 10% of its Net Profit to a Reserve Fund and deposit it in the form of Fixed Deposit in the Cooperative Bank. Now this action of the assessee is purely based on the Rules and Regulations provided under the West Bengal Cooperative Societies Act, 2006, which governs such Cooperative Societ....