THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S.SAHYADRI CO-OPERATIVE CREDIT SOCIETY LTD.
The appeal is disposed of as indicated above
ITA/196/2019HC Kerala04 Sept 2024
Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.
For Appellant: THE PRINCIPAL COMMISSIONER OF INCOME TAXFor Respondent: M/S. SAHYADRI CO-OPERATIVE CREDIT SOCIETY LTD
…T v. S.R. M. B. Dairy Farming (P.) Ltd. reported in [2018] 13 SCC 239¹. This court after considering the decisions of different High Courts, including the Supreme Court decision on the question involved, namely, CIT v. Surya Herbal Ltd. reported in [2011] 15 SCC 4822 answered the question in favour of the assessee in the following words: "We are of the view that the matter needs to be put to rest and a clarity be obtained in view of the impact of this issue on pending cases before the High Courts as well as the cases which have been disposed of by various High Courts by applying the circular of 2011 to…