INCOME TAX OFFICER, WARD-1, UDUPI vs. KAMBADAKONE RYTARA SEVA SAHAKARI SANGHA LTD, UPPUNDA
Income Tax Appellate Tribunal, “A’’BENCH: BANGALORE
Before: SHRI LAXMI PRASAD SAHU & SHRI KESHAV DUBEY
PER KESHAV DUBEY, JUDICIAL MEMBER:
These appeals at the instance of the revenue are directed against the order of ld. CIT(A)/NFAC dated 13.8.2024 vide DIN &
Order No. ITBA/NFAC/S/250/2024-25/1067595085(1) for the AY
2017-18
and dated
16.8.2024
vide
DIN
&
Order
No.
ITBA/NFAC/S/250/2024-25/1067702135(1) for the assessment
ITA Nos.1929 & 1930/Bang/2024
KambadakoneRytaraSevaSahakariSangha Ltd., Uppunda
Page 2 of 32
year 2018-19 passed u/s 250 of the Income Tax Act, 1961 (in short
“The Act). The assessee has also filed cross objections for the AYs
2017-18 & 2018-19 in CO as mentioned above in the cause title.
Since the issue in both these appeals is common in nature, these are clubbed together, heard together and disposed of by this common order for the sake of convenience.
First, we take up ITA No.1929/Bang/2024 for adjudication. In this appeal, the assessee has raised the following grounds of appeal:
ITA Nos.1929 & 1930/Bang/2024
KambadakoneRytaraSevaSahakariSangha Ltd., Uppunda
Page 3 of 32
The assessee has raised the following grounds of cross objection for the AY 2017-18:
ITA Nos.1929 & 1930/Bang/2024
KambadakoneRytaraSevaSahakariSangha Ltd., Uppunda
Page 4 of 32
Brief facts of the case are that the assessee is a primary agricultural credit society registered under the provisions of Karnataka Co-operative Societies Act, 1959. The assessee is in the business of providing credit facilities to its members for their agriculture related activity, selling of fertilizers, manure and PDS distribution and other allied activities as permitted under its bye laws duly approved by the