2025 (3) TMI 2236

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....Smt. Leena Lal, Sr. D.R. ORDER PER: INTURI RAMA RAO, AM This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi [CIT(A)], dated 30.08.2024 for Assessment Year (AY) 2022-23. 2. Brief facts of the case are that the assessee is primary agricultural credit co-operative society registered under the Kerala Co-Operative Societies Act, 1969....

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....ave heard the rival contentions of both the parties and perused the material available on record. 6. Learned CIT- DR vehemently argued that such interest income could have hardly be held even derived from assessee's regular credit facilities made available to the members concerned. He further quotes PCIT & Anr. v. Totagars Co-operative Sales Society reported in (2017) 395 ITR 611 (Kar.) and sub....

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....ive, since we cannot accept the contention of the Revenue that the interest earned on those deposits loses its character as profits/gains attributable to the main business of the assessee. It is not as though the assessee in the instant case had used the surplus amount (the profit earned by it] for an investment or activity that was unrelated to its main business, and earned additional income by w....