2025 (3) TMI 2252

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....ri Rajesh Meshram, Sr. DR ORDER UNDER SECTION 254(1) OF INCOME TAX ACT PER PAWAN SINGH, JUDICIAL MEMBER; 1. This appeal by the assessee is directed against the order passed by National Face less Appeal Centre (NFAC)/ the CIT(A), dated 11.11.2024 passed under section 250 of the Income Tax Act, 1961 ("the Act") for the assessment year 2017-18. Though the assessee has raised multiple grounds....

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.... the decision of Hon'ble Apex Court in Totgars Co-operative Sale Society Ltd. vs. ITO, (2010) 188 Taxman 282 (SC) and Hon'ble Karnataka High Court in PCIT vs. Totagars Co-operative Sale Society (2017) 83 taxmann.com 140 (Karnataka). The ratio of decision relied upon by the AO is not applicable on the facts of the present case. It has been consistently held by various benches of Tribunal that co-op....

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....e have considered the submissions of both the parties and have gone through the orders of lower authorities. We have also deliberated on various case laws relied upon by the learned AR of the assessee. We find that grounds of appeal raised by the assessee is in fact covered by a series of decision by this Bench as well as other Co-ordinate Benches of Tribunal wherein it has been consistently held ....