Bangalore Club v. CIT

350 ITR 509Supreme Court of India2013#351 most cited

What is Bangalore Club v. CIT authority for?

The Supreme Court affirmed the doctrine of mutuality, holding that contributions received from and returned to members for a common purpose do not constitute taxable profits. However, income from transactions with non-members or interest earned from investments in external entities (like cooperative banks) may break the mutuality chain and be taxable under Section 56, falling outside the scope of Section 80P deductions.

247

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2014 to 2026.

Also referred to as

Bangalore Club v. CIT · mutuality principle · doctrine of mutuality · Section 80P · Section 80P(2)(d) · Section 56 · cooperative society income · interest income taxability · income from other sources · mutual undertaking · members club · taxation of clubs

Also reported as

29 Taxmann.com 295 SCC 509212 Taxmann 566

Sections most often in play

Section 143(3)Section 80P(2)(a)(i)Section 56Section 80P(2)(d)Section 254Section 142(1)Section 80PSection 80P(1)
Read the full judgment

Issues it is cited on

mutuality principledoctrine of mutualitysection 11(4a)proviso to section 2(15)section 80p(1)section 80p(4)section 2(15)section 80p(2)(d)section 10(23c)section 80p(2)(a)section 80p(2)(a)(i)section 80p(2)

Judgments citing Bangalore Club v. CIT

Andhra Pradesh Advocates Welfare Fund, Hyderabad vs. Income Tax Officer, Ward-8(2), Hyderabad

In the result, all the three appeals of the assessee are dismissed

ITA 664/HYD/2023[2018-19]Status: DisposedITAT Hyderabad24 Jul 2024AY 2018-19

Bench: SHRI K.NARASIMHA CHARY (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

For Appellant: Shri P.R. Suresh, C.AFor Respondent: Shri Kumar Pranav, CIT(DR) &
Section 23Section 3

…him, in the light of the Assessment order and the contentions raised by the assessee, learned CIT(A), however, observed that the Learned Assessing Officer's decision to deny the exemption on the principles of mutuality was correct. In Bangalore Club vs. CIT (350 ITR 509), Hon’ble Supreme Court established that there must be a complete identity between contributors and participants, and the transactions should not be tainted by commerciality. The Learned Assessing Officer noted that some contributors are not beneficiaries, and clients, rather than advocates, often pay the fees. Thus, the principle of mutuality, w…

Andhra Pradesh Advocates Welfare Fund, Hyderabad vs. Income Tax Officer, Ward 8(2), Hyderabad

In the result, all the three appeals of the assessee are dismissed

ITA 663/HYD/2023[2017-18]Status: DisposedITAT Hyderabad24 Jul 2024AY 2017-18

Bench: SHRI K.NARASIMHA CHARY (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

For Appellant: Shri P.R. Suresh, C.AFor Respondent: Shri Kumar Pranav, CIT(DR) &
Section 23Section 3

…him, in the light of the Assessment order and the contentions raised by the assessee, learned CIT(A), however, observed that the Learned Assessing Officer's decision to deny the exemption on the principles of mutuality was correct. In Bangalore Club vs. CIT (350 ITR 509), Hon’ble Supreme Court established that there must be a complete identity between contributors and participants, and the transactions should not be tainted by commerciality. The Learned Assessing Officer noted that some contributors are not beneficiaries, and clients, rather than advocates, often pay the fees. Thus, the principle of mutuality, w…

Andhra Pradesh Advocates Welfare Fund, Hyderabad vs. Income Tax Officer, Ward 8(2), Hyderabad

In the result, all the three appeals of the assessee are dismissed

ITA 662/HYD/2023[2016-17]Status: DisposedITAT Hyderabad24 Jul 2024AY 2016-17

Bench: SHRI K.NARASIMHA CHARY (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

For Appellant: Shri P.R. Suresh, C.AFor Respondent: Shri Kumar Pranav, CIT(DR) &
Section 23Section 3

…him, in the light of the Assessment order and the contentions raised by the assessee, learned CIT(A), however, observed that the Learned Assessing Officer's decision to deny the exemption on the principles of mutuality was correct. In Bangalore Club vs. CIT (350 ITR 509), Hon’ble Supreme Court established that there must be a complete identity between contributors and participants, and the transactions should not be tainted by commerciality. The Learned Assessing Officer noted that some contributors are not beneficiaries, and clients, rather than advocates, often pay the fees. Thus, the principle of mutuality, w…

M/S. Punyabhoomi Welfare Service Society, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 528/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad03 Jul 2024AY 2018-19

Bench: Shri Ramit Kochar (Accountant Member)

For Appellant: Shri Varis Isani, AdvocateFor Respondent: Shri M. Anand Kumar, Sr. D.R
Section 139Section 143(1)Section 154Section 80PSection 80P(2)(a)

…The claims and contentions of the assessee both on legal as well factual aspects requires verification by the authorities below. At this stage it will be appropriate to refer to the decision of Hon’ble Supreme Court in the case of Bangalore Club v. CIT (2013) 350 ITR 509(SC) and the decision of Hon’ble Supreme Court in the case of ITO v. Venkatesh Premises Co-operative Society Limited (2018) 402 ITR 670(SC). Thus, keeping in view overall facts and circumstances of the case and in the interest of justice, I am remanding the matter back to the file of ld. CIT(A) to reconsider the contentions , claims as well evide…

Rajpath Club Ltd., Ahmedabad vs. The DCIT, Circle-3(1)(2), Ahmedabad

ITA 2420/AHD/2018[2015-16]Status: DisposedITAT Ahmedabad28 Jun 2024AY 2015-16

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Biren Shah, ARFor Respondent: Ms. Saumya Pandey Jain, Sr DR
Section 250(6)

…complete identity between the contributors and the participators of the funds. In the and 2420/Ahd/18 - Rajpath Club Ltd Vs. ACIT AY : 2008-09, 2012-13, 2013-14 & 2015-16 landmark judgment in the case of M/s. Bangalore Club Vs. CIT & Anr, reported in (2013) 350 ITR 509 (SC), the Hon’ble Apex Court held that the first condition required for applying the principle of mutuality is that there must be a complete identity between the contributors and the participators. The Hon’ble Apex Court noted that this was first laid down by Lord Macmillan in Municipal Mutual Insurance Ltd. Vs. Hills, wherein it was observed tha…

Rajpath Club Ltd., Ahmedabad vs. The Deputy Commissioner of Income Tax, Circle-3(1)(2), Ahmedabad

ITA 274/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad28 Jun 2024AY 2013-14

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Biren Shah, ARFor Respondent: Ms. Saumya Pandey Jain, Sr DR
Section 250(6)

…complete identity between the contributors and the participators of the funds. In the and 2420/Ahd/18 - Rajpath Club Ltd Vs. ACIT AY : 2008-09, 2012-13, 2013-14 & 2015-16 landmark judgment in the case of M/s. Bangalore Club Vs. CIT & Anr, reported in (2013) 350 ITR 509 (SC), the Hon’ble Apex Court held that the first condition required for applying the principle of mutuality is that there must be a complete identity between the contributors and the participators. The Hon’ble Apex Court noted that this was first laid down by Lord Macmillan in Municipal Mutual Insurance Ltd. Vs. Hills, wherein it was observed tha…

Rajpath Club Ltd., Ahmedabad vs. The Asstt. Commissioner of Income Tax, Circel-5, Ahmedabad

ITA 3084/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad28 Jun 2024AY 2012-13

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Biren Shah, ARFor Respondent: Ms. Saumya Pandey Jain, Sr DR
Section 250(6)

…complete identity between the contributors and the participators of the funds. In the and 2420/Ahd/18 - Rajpath Club Ltd Vs. ACIT AY : 2008-09, 2012-13, 2013-14 & 2015-16 landmark judgment in the case of M/s. Bangalore Club Vs. CIT & Anr, reported in (2013) 350 ITR 509 (SC), the Hon’ble Apex Court held that the first condition required for applying the principle of mutuality is that there must be a complete identity between the contributors and the participators. The Hon’ble Apex Court noted that this was first laid down by Lord Macmillan in Municipal Mutual Insurance Ltd. Vs. Hills, wherein it was observed tha…

Rajpath Club Ltd., Ahmedabad vs. The Asstt. Commissioner of Income Tax, Circel-5, Ahmedabad

ITA 3083/AHD/2016[2008-09]Status: DisposedITAT Ahmedabad28 Jun 2024AY 2008-09

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Biren Shah, ARFor Respondent: Ms. Saumya Pandey Jain, Sr DR
Section 250(6)

…complete identity between the contributors and the participators of the funds. In the and 2420/Ahd/18 - Rajpath Club Ltd Vs. ACIT AY : 2008-09, 2012-13, 2013-14 & 2015-16 landmark judgment in the case of M/s. Bangalore Club Vs. CIT & Anr, reported in (2013) 350 ITR 509 (SC), the Hon’ble Apex Court held that the first condition required for applying the principle of mutuality is that there must be a complete identity between the contributors and the participators. The Hon’ble Apex Court noted that this was first laid down by Lord Macmillan in Municipal Mutual Insurance Ltd. Vs. Hills, wherein it was observed tha…

The Institute of Indian Foundrymen, Kolkata vs. ITO, Ward 1(3), Exemption, Kolkata

In the result, the appeal of the assessee is allowed

ITA 499/KOL/2024[2018-19]Status: DisposedITAT Kolkata28 Jun 2024AY 2018-19

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey]

Section 11Section 12ASection 2(15)

…se of Secunderabad club vs. CIT (supra) has dealt with the principle of mutuality and thus the relevant part is extracted below: “31. While considering the triple test for applying the principle of mutuality, we find that in the case of Bangalore Club [2013] 350 ITR 509 (SC), the aforesaid triple test was applied. It was reiterated that the principle of mutuality envisages: 13 I.T.A. No.499/Kol/2024 Assessment Year: 2018-19 The Institute of Indian Foundrymen i) Complete identity between the contributors and participators; ii) Action of the participators and contributors must be in furtherance of the mandate of…

Murude Sahakari Patsanstha Maryadit, Mumbai vs. Income Tax Officer, Ward-22(2)(1), Mumbai

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1605/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Jun 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2016-17

For Appellant: Mr. Dharan GandhiFor Respondent: Ms. Usha Gaikwad, Sr. DR
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SANDEEP SINGH KARHAIL (JUDICIAL MEMBER) Assessment Year: 2016-17 Murude Sahakari Patsanstha ITO, Ward-22(2)(1), Maryadit, Room No. 312, 3rd floor, Vs. 58 Shivaji Jagar, N. M. Joshi Piramal Chamber, Lalbaug, Marg, Lower Parel, Parel, Mumbai-400012. Mumbai-400013. PAN NO. AADAM 0757 C Appellant Respondent Assessee by : Mr. Dharan Gandhi Revenue by : Ms. Usha Gaikwad, Sr. DR Date of Hearing : 20/06/2024 : 21/06/2024 Date of pronouncement ORDER PER OM PRAKASH KANT, AM This appeal by the assessee…

ACIT (Exemptions), Circle-2, Chandigarh vs. Infrastructure Development Fund, Chandigarh

In the result, the Departmental appeal is dismissed

ITA 336/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh29 May 2024AY 2012-13

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 336/Chd/2023 "नधा"रण वष" / Assessment Year : 2012-13 The Acit (Exemptions), Vs. Infrastructure Development Fund, बनाम Circle-2, Town & Country Planning, Chandigarh Haryana, Ayojna Bhawan, Sector 18 Marg, Chandigarh 160018 "थायी लेखा सं./Pan No: Aaal10136K अपीलाथ" ./ Appellant ""यथ" / Respondent

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Shri Rohit Sharma, CIT DR

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH, ‘A’, CHANDIGARH BEFORE SHRI A.D. JAIN, VICE PRESIDENT & DR KRINWANT SAHAY, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 336/CHD/2023 "नधा"रण वष" / Assessment Year : 2012-13 The ACIT (Exemptions), Vs. Infrastructure Development Fund, बनाम Circle-2, Town & Country Planning, Chandigarh Haryana, Ayojna Bhawan, Sector 18 Marg, Chandigarh 160018 "थायी लेखा सं./PAN No: AAAL10136K अपीलाथ" ./ Appellant ""यथ" / Respondent "नधा"रती क" ओर से/Assessee by : Sh. Parikshit Aggarwal, CA राज"व क" ओर से/ Revenue by : Shri Rohit Sharma, C…

Mudur Vyavasaya Seva Sahakari Sangha Ltd., Udupi vs. Income Tax Officer, Ward-2, Udupi

ITA 78/BANG/2024[2017-18]Status: DisposedITAT Bangalore29 May 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Mahesh R. Uppin, AdvocateFor Respondent: Shri V. Parithivel, Jt.CIT(DR)(ITAT), Bengaluru
Section 143(1)Section 18Section 40A(7)Section 43(2)Section 56Section 80P

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER Assessment year : 2017-18 Mudur Vyavasaya Seva Sahakari Vs. The Income Tax Officer, Sangha Ltd., Ward 2, Mudur – 576 233. Udupi. Kundapura Taluk, Udupi District. PAN : AAAAM 5489N APPELLANT RESPONDENT Appellant by : Shri Mahesh R. Uppin, Advocate Respondent by : Shri V. Parithivel, Jt.CIT(DR)(ITAT), Bengaluru. Date of hearing : 28.03.2024 Date of Pronouncement : 29.05.2024 O R D E R Per Laxmi Prasad Sahu, Accountant Member This appeal is filed by the assessee again…

The Mullanpur Garibdas Co-Op Multipurpose Society, Mohali vs. DCIT, C-6(1), Mohali

ITA 645/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh16 May 2024AY 2012-13

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Garima Singh, CIT, DR
Section 263Section 56Section 80PSection 80P(2)(d)

…sessee had invested with a cooperative bank and not with a cooperative society and hence, it was not eligible for deduction under section 80P(2)(d). To reject the claim of the assessee society, the PCIT has placed reliance on the decision in 'Bangalore Club', 350 ITR 509 (SC) and that in 'M/s Totagars Cooperative Sale Society Limited', 322 ITR 283 (SC). 14. The assessee society, on the other hand, has sought to place reliance on 'PCIT Versus Totagars Cooperative Sale Society', 392 ITR 74 (Karnataka) and 'Doaba Co-operative Sugar Mills Limited', 322 ITR 283 (P&H). 15. In the Assessment Order, the AO has obse…

The Mullanpur Garibdas Co-Op Multipurpose Society, Mullanpur vs. Pr. CIT-II, Chandigarh

ITA 569/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh16 May 2024AY 2013-14

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Garima Singh, CIT, DR
Section 263Section 56Section 80PSection 80P(2)(d)

…sessee had invested with a cooperative bank and not with a cooperative society and hence, it was not eligible for deduction under section 80P(2)(d). To reject the claim of the assessee society, the PCIT has placed reliance on the decision in 'Bangalore Club', 350 ITR 509 (SC) and that in 'M/s Totagars Cooperative Sale Society Limited', 322 ITR 283 (SC). 14. The assessee society, on the other hand, has sought to place reliance on 'PCIT Versus Totagars Cooperative Sale Society', 392 ITR 74 (Karnataka) and 'Doaba Co-operative Sugar Mills Limited', 322 ITR 283 (P&H). 15. In the Assessment Order, the AO has obse…

The Mullanpur Garibdas Co-Op Multipurpose Society, Mohali vs. Pr. CIT-II, Chandigarh

ITA 515/CHANDI/2017[2012-13]Status: DisposedITAT Chandigarh16 May 2024AY 2012-13

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Garima Singh, CIT, DR
Section 263Section 56Section 80PSection 80P(2)(d)

…sessee had invested with a cooperative bank and not with a cooperative society and hence, it was not eligible for deduction under section 80P(2)(d). To reject the claim of the assessee society, the PCIT has placed reliance on the decision in 'Bangalore Club', 350 ITR 509 (SC) and that in 'M/s Totagars Cooperative Sale Society Limited', 322 ITR 283 (SC). 14. The assessee society, on the other hand, has sought to place reliance on 'PCIT Versus Totagars Cooperative Sale Society', 392 ITR 74 (Karnataka) and 'Doaba Co-operative Sugar Mills Limited', 322 ITR 283 (P&H). 15. In the Assessment Order, the AO has obse…

Mudur Vyavasaya Seva Sahakari Sangha Ltd., Udupi vs. Income Tax Officer, Ward-1 & Tps, Udupi

ITA 299/BANG/2024[2020-21]Status: DisposedITAT Bangalore14 May 2024AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2020-21

For Appellant: Shri Mahesh R. Uppin, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 143(1)Section 18Section 2(24)(viia)Section 56Section 80GSection 80PSection 80P(2)(a)Section 8P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER Assessment year : 2020-21 Mudur Vyavasaya Seva Sahakari Vs. The Income Tax Officer, Sangha Ltd., Ward1 & TPS, Mudur – 576 233. Udupi. Kundapura Taluk, Udupi District. PAN : AAAAM 5489N APPELLANT RESPONDENT Appellant by : Shri Mahesh R. Uppin, Advocate Respondent by : Shri Ganesh R. Ghale, Standing Counsel. Date of hearing : 21.03.2024 Date of Pronouncement : 21.03.2024 O R D E R Per Laxmi Prasad Sahu, Accountant Member This appeal is filed by the assesse…

The Institute of India Foundrymen, Kolkata vs. ITO, Ward-1(3), Exempt, Kolkata.

In the result, the appeals of the assessee are allowed

ITA 1230/KOL/2023[2017-18]Status: HeardITAT Kolkata12 Apr 2024AY 2017-18

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 11Section 12ASection 2(15)

…ase of Secunderabad club vs. CIT (supra) has dealt with the principle of mutuality and thus the relevant part is extracted below: “31. While considering the triple test for applying the principle of mutuality, we find that in the case of Bangalore Club [2013] 350 ITR 509 (SC), the aforesaid triple test was applied. It was reiterated that the principle of mutuality envisages: i) Complete identity between the contributors and participators; ii) Action of the participators and contributors must be in furtherance of the mandate of the associations or the clubs. The mandate of the Club is a question of fact which has…

The Institute of Indian Foundrymen., Kolkata vs. ITO, Ward-1(3), Exempt, Kolkata.

In the result, the appeals of the assessee are allowed

ITA 1229/KOL/2023[2016-17]Status: HeardITAT Kolkata12 Apr 2024AY 2016-17

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 11Section 12ASection 2(15)

…ase of Secunderabad club vs. CIT (supra) has dealt with the principle of mutuality and thus the relevant part is extracted below: “31. While considering the triple test for applying the principle of mutuality, we find that in the case of Bangalore Club [2013] 350 ITR 509 (SC), the aforesaid triple test was applied. It was reiterated that the principle of mutuality envisages: i) Complete identity between the contributors and participators; ii) Action of the participators and contributors must be in furtherance of the mandate of the associations or the clubs. The mandate of the Club is a question of fact which has…

The Institute of Indian Foundrymen, Kolkata vs. ITO, Ward- 1(3), Exempt, Kolkata.

In the result, the appeals of the assessee are allowed

ITA 1228/KOL/2023[2015-16]Status: HeardITAT Kolkata12 Apr 2024AY 2015-16

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 11Section 12ASection 2(15)

…ase of Secunderabad club vs. CIT (supra) has dealt with the principle of mutuality and thus the relevant part is extracted below: “31. While considering the triple test for applying the principle of mutuality, we find that in the case of Bangalore Club [2013] 350 ITR 509 (SC), the aforesaid triple test was applied. It was reiterated that the principle of mutuality envisages: i) Complete identity between the contributors and participators; ii) Action of the participators and contributors must be in furtherance of the mandate of the associations or the clubs. The mandate of the Club is a question of fact which has…

Mudur Vyavasaya Seva Sahakari Sangha Ltd, Udupi vs. Income Tax Officer, Ward-1 & Tps, Udupi

ITA 1038/BANG/2023[2018-19]Status: DisposedITAT Bangalore22 Mar 2024AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2018-19

For Appellant: Shri Mahesh R Uppin, AdvocateFor Respondent: Dr. Nischal .B, Addl. CIT (DR)
Section 18Section 56Section 80P

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER Assessment Year : 2018-19 M/s. Mudur Vyavasaya Seva Sahakari Sangha Ltd., The Income Tax Mudur, Officer, Kundapura Taluk, Ward – 1, Udupi District – 576 233. Udupi. Vs. PAN: AAAAM5489N APPELLANT RESPONDENT Assessee by : Shri Mahesh R Uppin, Advocate Revenue by : Dr. Nischal .B, Addl. CIT (DR) Date of Hearing : 29-01-2024 Date of Pronouncement : 22-03-2024 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal arises out of order passed by the NFAC, Delhi dated 18.09…