CHHATTISGARH RAJYA LAGHU VANOPAJ VYAPAR AMD VIKAS SAHKARI SANGH MARYADIT, RAIPUR,RAIPUR vs. PR. COMMISSIONER OF INCOME TAX, RAIPUR-1, RAIPUR

These appeals pertaining to the Assessment Years (‘AYs’) 2015-16, 2016- 17, 2017-18 & 2018-19 originate against orders passed under section 263 of the Income Tax Act, 1961 (‘Act’) by the Ld. Principal Commissioner of Income Tax- Raipur-1 (‘PCIT’) as under:

The ITA No. 366/RPR/2026 is taken as a lead case. Almost all grounds raised in the above captioned four appeals are similar; therefore, the effective grounds of ITA No. 366/RPR/2026, for the sake of convenience, is reproduced hereunder:

The assessee, engaged in the business of trading and marketing of minor forest produce, filed its original Income Tax Return (‘ITR’) on 30.09.2015 of the relevant year declaring NIL income. Subsequently, the case was picked up for limited scrutiny. Original assessment was, thereafter, completed at income of Rs.65,16,305/- under section 143(3) of the Act on 20.12.2017. The Ld. AO made addition under section 36(1)(va) read with section 24(x) of the Act. The assessee has earned interest of Rs.4,52,47,245/- on the FDRs duly disclosed as Interest Earned on Federation Seed Capital [Page 34 of the Paper Book (PB)]. The said interest of Rs.4,52,47,245/-, in the scrutiny assessment, was allowed as deduction under chapter VIA by the Ld. AO. The said FDRs has been made out of seed money as disclosed in the Balance Sheet of the assessee for the relevant Financial Year (‘FY’) (Page 38 of the PB). Later on, the Ld. PCIT, invoking the revisionary power under section 263 of the Act, set aside the assessment order passed under section 143(3) of the Act on 20.12.2017 and directed the Ld. AO to make afresh assessment on various issues mentioned in the order dated 30.03.2021 passed under section 263 of the Act. The said order of the Ld. PCIT went up before the Hon’ble High Court, who vide its order dated 22.07.2024 passed in TAXC No.164 of Chhattisgarh Rajya Laghu Vanopaj Vypar and Vikas Sahkari Sangh Maryadit,Vs. PCIT

At the outset, Shri R. B. Doshi, CA, Ld. Authorized Representative (‘AR’) of the assessee drew our attention to the fact that the Ld. AO did not draw any adverse inference in consequential set aside assessment order dated 21.03.2026 passed under section 143(3) rws 263 of the Act with respect to the issues raised vide Ground Nos. 2, 4 and 5 in this appeal. Hence, the assessee, as of now was not aggrieved with Ground Nos. 2, 4 and 5. But the issue remained here that whether the LD. PCIT, on these issues, was justified in holding the assessment order as erroneous and prejudicial to the interests of the revenue. He submitted that the interest on FDRs of Rs.394,82,24,597/- was not the assessee’s income as the FDRs of Rs.394,82,24,597/- was held in fiduciary capacity and that was why the interest income on the same was disclosed in the Agency P & L Account and the FDRs of Rs.394,82,24,597/- as non-Federation asset in the balance sheet of the relevant year. He drew our attention to pages 34, 38 and 39 of the PB.

The Ld. AR, further drawing our attention to pages 124 to 231 of the PB, submitted that the assessments of AYs 2009-10 to 2014-15 were scrutinized and were completed under section 143(3) of the Act accepting the returned incomes. Since all submissions filed during the assessment proceedings of AYs 2009-10 to 2014-15 were accepted by the Ld. AO. Hence, the issues flagged by the Ld. PCIT in the impugned order had attained finality in the past. Hence, some of the Ld. AOs, for the first time investigating the case assessee, might have raised the settled issues during the course of assessments. But they have accepted the assessee’s submissions and did not draw the adverse inference thereon. Since the assessee could not suggest and dictate the way investigations required to be carried out during the assessment proceedings; therefore, some of the Ld. AOs might have discussed or not discussed the issues flagged by the Ld. PCIT in the impugned order. Since these issues were repetitive in nature over the years; therefore, the Ld. AO, most of the time did not raise such issues during the assessment proceedings. Since the issues flagged by the Ld. PCIT in the impugned order get explained from the perusal of clear cut narrations mentioned in the Agency Trading and P & L Account & Federation P & L Account and the consolidated Balance Sheet of the relevant year. Therefore, the issues flagged by the Ld. PCIT in the impugned order did not have any merit and justification. The Ld. AR, therefore, prayed for quashing the impugned order in this regard.

As far as the issue relating to the deduction under section 80P(2)(d) of the Act, the Ld. AR drew our attention to the fact that the Ld. AO had allowed the deduction under section 80P(2)(d) of the Act but did not give any justification for that. Since this issue was recurring and allowed in favour of the assessee since now; therefore, it appeared that the Ld. AO did not prefer writing any detailed justification on the allowability of deduction under section 80P(2)(d) of the Act. However, she had allowed the claim of deduction of Rs.4,52,47,245/- under section 80P(2)(d) of the Act while computing the income in paragraph 7 (page No. 10 of the assessment order). Thus, the Ld. AO took a plausible view sustainable in the eyes of law and allowed the deduction of Rs.4,52,47,245/- under section 80P(2)(d) of the Act. Hence, such assessment order could not be reviewed again due to change of opinion, submitted the Ld. AR. He placed reliance on following decisions:  Gramin Sewa Sahakari Samiti Maryadit vs. ITO in ITA no. 108/RPR/2022 dt. 16.08.2023  Pr. CIT vs. Totagars Co-operative Sale Society (2017) 392 ITR 74 (Karn.)  Karmaveer Bhaurao Patil Nagri Sahahkari Patsanstha Maryadit vs. ITO in ITA no. 1045, 1046/Pune/2023 dt. 21.02.2024  Kirloskar Oil Engine Employees Cooperation Credit Society Ltd. vs. PCIT in ITA no. 605/Pun./2023 dt. 16.06.2023  Navrang Basant Co-operative Housing Society Ltd. vs. ITO in ITA no. 1353/Mum/2023 dt. 11.10.2023  Shri Durga Gram Service Co-operative Society Ltd. vs. ITO ITA no. 535/RPR/2025 dt. 09.10.2025

The Ld. AR, further drawing our attention to the finding of the Tribunal in 1st round of appeal in the case of the assessee on the issue of deduction under section 80P(2)(d) of the Act, submitted that the Tribunal, in principle admitted the allowability of deduction under section 80P(2)(d) of the Act. But, the Tribunal holding that the Ld. AO did not investigate that whether such interest was earned from Cooperative Bank, upheld the order passed under section 263 of the Act for limited purpose only. The relevant part of the Tribunal order in ITA Nos.47, 48 & 49/RPR/2021 dated 09.05.2024 reads as under:

Admittedly, as observed by the Pr.CIT the interest of Rs.6,02,40,190/- (supra) was earned by the assessee society during the year on its seed capital. On further perusal of the record, it transpires that the assessee society had claimed to have received interest income on its FDR (sourced out of its seed capital) with "Apex bank". In so far the entitlement of a co-operative society for deduction u/s. 80P(2)(d) of the interest income received on deposits lying with a co-operative bank is concerned, we find that the said issue is squarely covered by the order of the ITAT, Mumbai in the case of M/s. Solitaire CHS Ltd. Vs. Pr. Commissioner of income Tax-26, Mumbai, ITA No.3155/MUM/2019 dated 29.11.2019. The Tribunal after deliberating at length on the various facets of the issue in hand, i.e. entitlement of a co- operative society for claiming deduction of interest on deposits lying with a co- operative bank u/s. 80P(2)(d) of the Act, had observed as under:

We have heard the authorised representatives for both the parties, perused the orders of the lower authorities and the material available on record, as well as the judicial pronouncements relied upon by them. Our indulgence in the present appeal has been sought, for adjudicating, as to whether the claim of the assessee for deduction under section 80P(2)(d) in respect of interest income earned from the investments/deposits made with the co-operative banks is in order, or not. In our considered view, the issue involved in the present appeal revolves around the adjudication of the scope and gamut of sub-section (4) of Sec. 80P as had been made available on the statute, vide the Finance Act 2006, with effect from 01.04.2007. On a perusal of the order passed by the Pr. CIT under Sec. 263 of the Act, we find, that he was of the view that pursuant to insertion of Chhattisgarh Rajya Laghu Vanopaj Vypar and Vikas Sahkari Sangh Maryadit,Vs. PCIT

After necessary deliberations, we are unable to persuade ourselves to be in agreement with the view taken by the Pr. CIT. Before proceeding any further, we may herein reproduce the relevant extract of the aforesaid statutory provision, viz. Sec. 80P(2)(d), as the same would have a strong bearing on the adjudication of the issue before us. “80P(2)(d) (1). Where in the case of an assessee being a co-operative society, the gross total income includes any income referred to in subsection (2), there shall be deducted, in accordance with and subject to the provisions of this section, the sums specified in sub-section (2), in computing the total income of the assessee. (2). The sums referred to in sub-section (1) shall be the following, namely:- (a)......... (b)......... (c)......... (d) in respect of any income by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society, the whole of such income;”

We shall now advert to the judicial pronouncements that have been relied upon by the ld. A.R. We find that the issue that a co-operative society would be entitled for claim of deduction under Sec. 80P(2)(d) on the interest income derived from its investments held with a co-operative bank is covered in favour of the assessee in the following cases:

Be that as it may, in our considered view, as the A.O while framing the assessment had taken a possible view, and therein concluded that the assessee would be entitled for claim of deduction under Sec. 80P(2)(d) on the interest income earned on its investments/deposits with co-operative banks, therefore, the Pr. CIT was in error in exercising his revisional juri iction u/s 263 for dislodging the same. In fact, as observed by us hereinabove, the aforesaid view taken by the A.O at the time of framing of the assessment was clearly supported by the order of the juri ictional (2017) 46 CCH 52 (Mum). Accordingly, finding no justification on the part of the Pr. CIT, who in exercise of his powers under Sec. 263, had dislodged the view that was taken by the A.O as regards the eligibility of the assessee towards claim of deduction under Sec. 80P(2)(d), we „set aside‟ his order and restore the order passed by the A.O under Sec. 143(3), date 14.09.2016. 10. Resultantly, the appeal filed by the assessee is allowed."

Although, we are principally in agreement with the Ld. AR that the interest income received by a co-operative society on its deposits with a co-operative bank would be entitled for deduction u/s. 80P(2)(d) of the Act, but at the same time, we find from a perusal of the record that the A.O while framing the assessment had at no stage verified the authenticity of the claim of the assessee society that the deduction raised by it u/s. 80P(2)(d) of the Act pertained to the interest income on its deposits parked with a co-operative bank/banks. As nothing is discernible from the record nor any material has been filed before us in the course of hearing of the appeal, which would reveal that the assessee's claim for deduction u/s. 80P(2)(d) of the Act was raised as regards the interest income earned on its deposits lying with a co-operative bank/banks, therefore, to the said extent, we concur with the Pr. CIT that the A.O without carrying out any verification on the aforesaid material aspect had Chhattisgarh Rajya Laghu Vanopaj Vypar and Vikas Sahkari Sangh Maryadit,Vs. PCIT

The Ld. AR, drawing our attention to page 124 to 218 of PB containing the financial details of AYs 2009-10, 2010-11, 2011,12, 2012,13, 2013-14 and 2014-15, submitted that the interest on investment on which the deduction of Rs.4,5247,245/- claimed was FDRs with Cooperative Bank. The Ld. AR drew our attention to page 14 & 15 of the PB (submission dated 06.02.2025 filed before the Ld. PCIT) to submit that the assessee had filed a certificate issued by the Chhattisgarh Rajya Sahkari Bank Maryadit admitting the said FDRs of the assessee with it, which resulted interest of Rs.4,5247,245/-. Thus, the assessee had demonstrated before the Ld. PCIT that the said FDRs of the assessee were with Cooperative Bank. Hence, the Ld. PCIT, ignoring not only the Hon’ble High Court direction to consider the assessee’s submission but also the Tribunal finding as scanned above, set aside the assessment order on this score and directed the Ld. AO to do inquiries/verification and to pass the assessment order afresh on this score too. Thus, the impugned order needed to be quashed as the Ld. PCIT acted against the Hon’ble High Court’s order and Tribunal’s order in the case of the assessee. The Ld. AR further submitted that the Ld. AO, in consequential order, disallowed the claim of deduction of Rs.4,5247,245/- under section 80P(2)(d) of the Act.

The Ld. AR drew our attention to the decision the Hon’ble Supreme Court in the case of Radhasaomi Satsang vs. CIT (1992) 193 ITR 321 (SC) and submitted that the Revenue following the principle of consistency, should have not disturbed the already settled issues over the years. He contended that the issue which had already examined and settled in preceding years should not be revisited again if there was no change in facts.

On our specific query, the Ld. AR was quite fair enough to admit that the Ld. AO had not raised any specific enquiry with respect to the claim of deduction under section 80P(2)(d) of the Act in ITA Nos. 366, 368 & 369/RPR/2025 pertaining to AYs 2015-16 and 2018-19. However, in the ITA No.367/RPR/2025 for AY 2016-17, the Ld. AO had raised specific query (Query Nos. 3 & 4 page 55 of the PB of AY 2016-17), which were duly replied (page 65 to 68 of the PB of AY 2016-17). The Ld. AO was satisfied with the submission of the assessee and did not draw any adverse inference. In other years the Ld. AO allowed the claim of deduction under section 80P(2)(d) of the Act. Further, the Ld. AR drew our attention to the page No. 62 to 65 of the PB of AY 2017-18, wherein the Ld. AO had raised the specific query on the issue of deduction under section 80P of the Act, which were duly replied (page 66 to 71 of the PB of AY 2017-18). The Ld. AR also drew our attention to page No. 58 of the Case Laws Paper Book, wherein he placed emphasis on the Tribunal’s decision in the case of Kirloskar Oil Engine Employees Co-op, Credit Society Limited vs. the PCIT-2, Pune in ITA No.605/PUN/2026 dated 16.06.2023, wherein it has been categorically held as under:

Thus, we find that the issue which is subject matter of revision is covered in favour of the assessee by judicial precedents. Therefore, it cannot be said that the assessment order is erroneous or prejudicial to the interests of the revenue. Therefore, we are of the considered opinion that the order of revision passed by the Id. PCIT u/s 263 of the Act cannot be sustained in the eyes of law. Hence, the grounds of appeal raised by the assessee stand allowed."”

The Ld. AR further contended that the issue of claim of deduction under section 80P(2)(d) of the Act had already been examined in detail by the Ld. AO in preceding years and that was why the Ld. AO did not narrate this issue in details in the assessment order. He submitted that issue of claim of deduction under section Chhattisgarh Rajya Laghu Vanopaj Vypar and Vikas Sahkari Sangh Maryadit,Vs. PCIT

The Ld. AR further submitted that the Ld. PCIT did not bother to look into the past record and detailed submission of the assessee even on merit also wherein it was specifically mentioned vide submission dated 21.02.2025 (Page No. 19 to 24 of the PB of AY 2015-16) that the issue of claim of deduction under section 80P(2)(d) of the Act was settled by the Tribunal in the assessee’s favour in 1st round of proceedings under section 263 of the Act.

The Ld. AR submitted that the Cooperative Banks from whom the assessee got interest were Cooperative Societies. He submitted that the Cooperative Society had been defined under section 2(19) of the Act. According to which such entity had to have registration under the Cooperative Societies Act, 1912 or any State Law. He submitted that the status of any Cooperative Society engaged in the business of banking would not get determined by the fact that the such Cooperative Society had banking license from the RBI. He placed reliance on the decision of Hon’ble Gujrat High Court in the case of Rajkot Ladhika Sahkari Kharid Vechan Sangh [2025] 176 taxmann.com 71. 20. The propositions/contentions of the Ld. AR, for brevity, are categorized into following heads: (i) It is not a case of lack of inquiries by the AO, (ii) The AO has taken a plausible view based on the outcome of inquiries/ verification and material available on the assessment record, (iii) It is a case of change of opinion.

Per contra, Shri Rituparna Namdeo, Ld. CIT-DR prayed for dismissal of the appeals placing emphasis on the impugned order. He submitted that the Ld. PCIT had categorically held that the original assessment order was erroneous and prejudicial to the interest of revenue including in terms of Explanations 2(a) and (b) to section 263 of the Act as the Ld. AO had not carried out the requisite inquiries and investigations. It was submitted by the Ld. CIT-DR that the Ld. AO while framing the assessment had without carrying out requisite inquiries/verification, summarily accepted the claim of deduction under section 80P(2)(d) of the Act.

We have heard rival parties at length and have perused the material available on the record. The issues tasked to us to adjudicate vide above mentioned 5 grounds are twofold:

First of all, we will adjudicate the 1st issue; i.e. the claim of deduction under section 80P(2)(d) of the Act. The legislative intent behind section 80P of the Act is the recognition that cooperative societies operate on principles different from commercial enterprise entities. These organizations; therefore, function to serve more the interest of members rather than profit maximization. By giving the tax incentive, the legislation is promoting the creation and sustenance of the cooperative societies for financial inclusion and, thus, rural development. Section 80P(2)(d) of the Act, in particular, allows complete deduction of interest income or dividend derived by a co-operative society from its investments in any other co- operative society. Undisputedly, the appellant assessee is a cooperative society. The Finance Act, 2006 introduced an amendment by adding sub-section (4) to Section 80P of the Act with effect from April 1, 2007. By this amendment, deduction under Section 80P of the Act was precluded as regards co-operative banks, barring the exceptions of primary agricultural credit societies and primary co-operative agricultural and rural development banks. The basis underlying the exclusion was the equivalence in the functional operation of the co-operative banks to that of the commercial banks as they were no longer different in functioning from the commercial banking institutions and were competing in the same relevant market. The provision categorically states that the deduction under section 80P of the Act shall not be allowed to any cooperative bank other than the two categories mentioned therein. The legislative history shows that the amendment was aimed at, and was intended to, take away the competitive advantage that cooperative banks enjoyed over commercial banks, claiming deductions under section 80P of the Act. CBDT Circular No. 14, dated 28.12.2006, explains that sub-section (4) was inserted to bring cooperative banks that operate at par with commercial banks on equal footing with regard to taxation treatment. This stipulation would be essential in considering the fact that the amendment’s scope was restricted to the denial of the deduction to cooperative banks.

The Tribunal, in 1st round of appellate proceedings in the case of the assessee in ITA Nos. 47, 48 & 49/RPR/2021 dated 09.05.2024, in principle, has held that the assessee’s interest income earned from the cooperative banks is eligible for deduction under section 80P(2)(d) of the Act. However, the Tribunal, vide its order dated 09.05.2024, holding that the AO has not ascertained the fact that whether the interest of Rs.4,52,47,245/- has earned from the cooperative banks, upheld the order passed under section 263 of the Act for this limited purpose on this score.

We find merit in the submission of the Ld. AR that the Tribunal, in principle, has allowed the claim of deduction under section 80P(2)(d) of the Act in assessee’s own case. Further, we also take note of the fact that the Ld. AO, by allowing the claim of deduction of Rs.4,52,47,245/- under section 80P(2)(d) of the Act, has taken a plausible view sustainable in the eyes of law though the Ld. AO has not given detailed justification for the same in the assessment order. It appears that the Ld. AO, knowing the facts of the case, past history of the assessee in details and recurring issue of claim of deduction under section 80P(2)(d) of the Act, may have not written detailed justification for allowing the claim of deduction under section 80P(2)(d) of the Act.

The Bank Certificate admitting the interest of Rs.4,52,47,245/- earned from cooperative bank has been filed before the Ld. PCIT vide the assessee’s submission dated 21.02.2025. After the submission of this certificate before the Ld. PCIT, the source from which such interest earned gets established. The Ld. PCIT has not doubted the said Bank Certificate admitting the interest of Rs.4,52,47,245/- earned from cooperative bank. The Balance Sheet and P & L Account of the assessee of the relevant year along with the ledger account of interest of Rs.4,52,47,245/- shown in the Federal P & L Account also justify the said Bank Certificate. We do not understand what else inquiries/verification, after the detailed submission of the assessee during the course of proceedings under section 263 of the Act, are left to be carried out by the Ld. AO for ascertaining the basic facts. It appears that the issue of claim of deduction of Rs.4,52,47,245/- under section Chhattisgarh Rajya Laghu Vanopaj Vypar and Vikas Sahkari Sangh Maryadit,Vs. PCIT

In Totgars’ Co-operative Sale Society Ltd. (supra), the dispute before the Hon’ble Supreme Court was that whether only the business income of a co- operative society was deductible under section 80P(2)(i) of the Act. The Hon’ble Supreme Court had held that ‘the whole of the amount of profits and gains of business’, in respect of which deduction was sought, must constitute the operational income and not the other income which accrued to the society. In the present case, the interest income of Rs.4,52,47,245/- receivable/received from Cooperative Bank has been claimed as deduction under section 80P(2)(i) of the Act, which has been allowed by the Ld. AO. Thus, we are of the considered view that the decision of Hon’ble Supreme Court in the case of Totgars’ Co-operative Sale Society Ltd. (supra) is not applicable on the issue of claim of deduction under section 80P(2)(i) of the Act.

We do agree with the finding of the Tribunal in the assessee’s own case in ITA Nos. 47, 48 & 49/RPR/2021; wherein the Tribunal, in principle, has held that the interest income earned from the cooperative banks is eligible for deduction under section 80P(2)(d) of the Act. Since the assessee has received interest of Rs.4,52,47,245/- from Cooperative Bank; therefore, the assessee is eligible for deduction under section 80P(2)(d) of the Act is one of the view which has been taken by the Ld. AO though not with detailed justification in the original assessment order. Writing of the assessment order is prerogative of the AO; some write detailed order some not. The way the assessment order written should not be sole the criteria for invoking section 263 of the Act.

The phrase "erroneous and prejudicial to the interests of revenue" has been subject to extensive judicial interpretation. In Malabar Industrial Co. Ltd. 243 ITR 83, the Hon’ble Supreme Court has held that an order is erroneous if it involves an incorrect assumption of facts or an incorrect application of law. However, if the AO has taken a possible and legally permissible view, the order cannot be deemed erroneous simply because the Commissioner has a different opinion. This principle has been further reinforced in many decisions later on. In view of the judicial pronouncements relied upon by the Ld. AR, we are of the considered view that the Ld. AO’s decision to allow the deduction under section 80P(2)(d) of the Act, being one of the possible and legally permissible view, cannot be revisited again under section 263 of the Act because the PCIT has a different opinion that too in particularly when the Tribunal in the assessee’s own case in ITA Nos. 47, 48 & 49/RPR/2021, in principle, has allowed the deduction under section 80P(2)(d) of the Act. We, therefore, are of the considered view that it is a case of change of opinion; hence, the section 263 of the Act cannot be invoked in the present case on the issue of claim of deduction under section 80P(2)(d) of the Act. Accordingly, we reversed the finding of the Ld. PCIT on the issue of claim of deduction under section 80P(2)(d) of the Act in the impugned order passed under section 263 of the Act and restore the finding in the original assessment order in this regard. Accordingly, we hold that the Ld. PCIT is not justified in invoking his revisionary power to hold that the claim of deduction under section 80P(2)(d) of the Act allowed by the Ld. AO is erroneous and prejudicial to the interests of the revenue and to direct the Ld. AO to do needful vide impugned order. Ground Nos. 1 and 3 stand allowed as above.

Now, we will adjudicate the 2nd issue raised vide Grounds 2, 4 and 5 of this appeal. The Ld. PCIT, invoking his revisionary power under section 263 of the Act, has held that the Ld. AO has not properly inquired/verified the issue of taxability of interest income earned on FDRs of Rs.394,82,24,597/- with various Banks other than Cooperative Banks and has directed the Ld. AO to revisit this issue afresh after setting aside the assessment order. In pursuance of the impugned order, the Ld. AO passed the assessment order dated 21.03.2026 under section 143(3) rws 263 of the Act and did not take any adverse view on the issue emerged from Ground Nos. 2, 4 and 5 of this appeal. Thus, the assessee, as of now is not aggrieved with Ground Nos. 2, 4 and 5 as the same have been decided in its favour by the Ld. AO in consequential proceedings. But the issue remained here is that whether the Ld. PCIT is justified in passing the impugned order on this issue. Since various aspects of the issue emerged from Ground Nos. 2, 4 and 5 of this appeal have not been threadbare by the Ld. AO while passing the original assessment order after carrying out the requisite inquiries/verification; therefore, we are convinced with the finding of the Ld. PCIT on this score and hold that the Ld. PCIT is justified in setting aside the original assessment order on the issue(s) emerged from Ground Nos. 2, 4 and 5 of Chhattisgarh Rajya Laghu Vanopaj Vypar and Vikas Sahkari Sangh Maryadit,Vs. PCIT

In the result, the appeal of the assessee is partly allowed as above.

The above finding shall apply mutatis mutandis in these appeals also.

In the result, the above captioned appeals of the assessee are partly allowed as above.

""थ"/ The Respondent

The Pr. CIT, Raipur (C.G.) 4. िवभागीय "ितिनिध, आयकर अपीलीय अिधकरण, रायपुर/ DR, ITAT, Raipur 5. गाड" फाईल / Guard file.