Goetze (India) Ltd. v. CIT

284 ITR 323Supreme Court of India2006#13 most cited

What is Goetze (India) Ltd. v. CIT authority for?

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

1,842

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2008 to 2026.

Also referred to as

Goetze (India) Ltd v CIT · new claim by assessee · additional ground · revised return of income · section 139(5) · Assessing Officer powers · CIT(A) powers · ITAT powers · assessment proceedings · fresh claim · 284 ITR 323

Also reported as

157 Taxmann 1204 CTR 182157 Taxmann.com 1

Sections most often in play

Section 143(3)Section 14A Section 115JB Section 37(1)Section 147 Section 153A Section 143(1)Section 250

Issues it is cited on

section 139(5)book profits section 115j revenue expenditure section 115jb capital expenditure disallowance under section 14a section 32 section 254 section 37(1)transfer pricing adjustment liable to tax

Judgments citing Goetze (India) Ltd. v. CIT

ACIT, New Delhi vs. M/S Gujarat Guardian Ltd., New Delhi

ITA 4791/DEL/2010[2004-05]Status: DisposedITAT Delhi16 Jul 2025AY 2004-05

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…e that this claim was not made before the AO during the re-assessment proceedings rather has been made for the first time before the ld. CIT(A) by way of additional ground. 27. The ld. CIT(A) relying upon the judgement of Goetz India Ltd. Vs. CIT reported in 284 ITR 323 dismissed the ground of the assessee by holding that assessee could have made this claim by filing revised return. 28. Counsel for the assessee appearing argued that the order of Goetz India Ltd. (supra) could not impinge upon the powers of Ld. CIT(A), therefore, the ld. CIT(A) erred in not admitting the claim of the assessee by way of additiona…

Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 159/DEL/2010[2003-04]Status: DisposedITAT Delhi16 Jul 2025AY 2003-04

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

…e that this claim was not made before the AO during the re-assessment proceedings rather has been made for the first time before the ld. CIT(A) by way of additional ground. 27. The ld. CIT(A) relying upon the judgement of Goetz India Ltd. Vs. CIT reported in 284 ITR 323 dismissed the ground of the assessee by holding that assessee could have made this claim by filing revised return. 28. Counsel for the assessee appearing argued that the order of Goetz India Ltd. (supra) could not impinge upon the powers of Ld. CIT(A), therefore, the ld. CIT(A) erred in not admitting the claim of the assessee by way of additiona…

Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 158/DEL/2010[2002-03]Status: DisposedITAT Delhi16 Jul 2025AY 2002-03

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R

…e that this claim was not made before the AO during the re-assessment proceedings rather has been made for the first time before the ld. CIT(A) by way of additional ground. 27. The ld. CIT(A) relying upon the judgement of Goetz India Ltd. Vs. CIT reported in 284 ITR 323 dismissed the ground of the assessee by holding that assessee could have made this claim by filing revised return. 28. Counsel for the assessee appearing argued that the order of Goetz India Ltd. (supra) could not impinge upon the powers of Ld. CIT(A), therefore, the ld. CIT(A) erred in not admitting the claim of the assessee by way of additiona…

DCIT, New Delhi vs. M/S. Gujrat Guardian Ltd., New Delhi

ITA 157/DEL/2010[2003-04]Status: DisposedITAT Delhi16 Jul 2025AY 2003-04

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R

…e that this claim was not made before the AO during the re-assessment proceedings rather has been made for the first time before the ld. CIT(A) by way of additional ground. 27. The ld. CIT(A) relying upon the judgement of Goetz India Ltd. Vs. CIT reported in 284 ITR 323 dismissed the ground of the assessee by holding that assessee could have made this claim by filing revised return. 28. Counsel for the assessee appearing argued that the order of Goetz India Ltd. (supra) could not impinge upon the powers of Ld. CIT(A), therefore, the ld. CIT(A) erred in not admitting the claim of the assessee by way of additiona…

DCIT, New Delhi vs. M/S Gujrat Guardian Ltd., New Delhi

ITA 4859/DEL/2009[2002-03]Status: DisposedITAT Delhi16 Jul 2025AY 2002-03

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R

…e that this claim was not made before the AO during the re-assessment proceedings rather has been made for the first time before the ld. CIT(A) by way of additional ground. 27. The ld. CIT(A) relying upon the judgement of Goetz India Ltd. Vs. CIT reported in 284 ITR 323 dismissed the ground of the assessee by holding that assessee could have made this claim by filing revised return. 28. Counsel for the assessee appearing argued that the order of Goetz India Ltd. (supra) could not impinge upon the powers of Ld. CIT(A), therefore, the ld. CIT(A) erred in not admitting the claim of the assessee by way of additiona…

Rekha Rani Gupta, Burdwan (East) vs. I.T.O., Ward - 1(1), Burdwan

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

ITA 1059/KOL/2024[2018-2019]Status: DisposedITAT Kolkata10 Jul 2025AY 2018-2019

Bench: Shri George Mathanआयकर अपील सं/Ita No.1059/Kol/2024 (नििाारण वर्ा / Assessment Year :2018-2019) Rekha Rani Gupta, Vs Ito, Ward-1(1), Burdwan Hossainpur, Purba Bardhaman Pin-713125 Pan No. : Bxvpg 1588 C (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Soumitra Choudhury, Advocate नििााररती की ओर से /Assessee By : Smt. Madhumita Das, Sr.Dr राजस्व की ओर से /Revenue By सुनवाई की तारीख / Date Of Hearing : 10/07/2025 घोषणा की तारीख/Date Of Pronouncement : 10/07/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 29.02.2024 For The Assessment Year 2018-2019. 2. Shri Soumitra Choudhury, Ld.Ar Appeared On Behalf Of The Assessee & Smt. Madhumita Das, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. It Was The Submission By The Ld. Ar That That The Assessee Had On The Basis Of The Form 26As Filed His Return Of Income. It Was The Submission That In The Form 26As It Was Shown That The Assessee Had Done Certain Contract Work For West Bengal State Electricity Board Burdwan Division. It Was The Submission That, In Fact, The Assessee Had Not Done Any Work. It Was The Submission That The West Bengal State Electricity Board Burdwan Division Had Also Clarified Before The Ao In Response To Notice U/S.133(6) Of The Act That The Assessee Has Not Done Any Work For Them. However, The Ao Added The Total Contract Amount As Shown In The Form 26As As Income

For Appellant: Smt. Madhumita Das, Sr.DR

Section 133(6)Section 140

…आयकर अपीलीय अधिकरण, “एस.एम.सी” न्यायपीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH KOLKATA श्री जाजज माथन, न्याययक सदस्य के समक्ष । BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER आयकर अपील सं/ITA No.1059/KOL/2024 (नििाारण वर्ा / Assessment Year :2018-2019) Rekha Rani Gupta, Vs ITO, Ward-1(1), Burdwan Hossainpur, Purba Bardhaman PIN-713125 PAN No. : BXVPG 1588 C (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Soumitra Choudhury, Advocate नििााररती की ओर से /Assessee by : Smt. Madhumita Das, Sr.DR राजस्व की ओर से /Revenue by सुनवाई की तारीख / Date of Hearing : 10/07/2025 घोषणा की तारीख/Date o…

Assistant Commissioner of Income Tax, Circle-1(1)(1), Ahmedabad vs. Arvind Limited, Ahmedabad

In the result, the appeal of the assessee is partly allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 466/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad03 Jul 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamblearvind Limited, Dcit Vs. Naroda Road, Nfac, Delhi Ahmedabad-380025 (Dcit, Circle 1(1)(1), [Pan : Aabca 2398 D] Ahmedabad) Arvind Limited, Vs. Acit, Circle 1(1)(1), Naroda Road, Ahmedabad Ahmedabad-380025 [Pan : Aabca 2398 D]

For Appellant: Shri Biren Shah, AR &For Respondent: Shri Prathvi Raj Meena, CIT-DR &

Section 115JSection 143(3)Section 14ASection 250

…tain deductions and benefits, which was based on facts and evidence already present in the Assessing Officer's records. The Assessing Officer did not allow such claim relying on the judgment of the Hon’ble Apex Court in the case of Goetze (India) Ltd. vs CIT, 284 ITR 323. The same reads as under:- “2. The question raised in this appeal relates to whether the appellant assessee could make a claim for deduction other than by filing a revised return. The assessment year in question was 1995-96. The return was filed on 30-11-1995, by the appellant for the assessment year in question. On 12- 1-1998, the appellant sou…

Arvind Limited, Ahmedabad vs. NFAC, Delhi Present Jurisdiction the DCIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 349/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad03 Jul 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamblearvind Limited, Dcit Vs. Naroda Road, Nfac, Delhi Ahmedabad-380025 (Dcit, Circle 1(1)(1), [Pan : Aabca 2398 D] Ahmedabad) Arvind Limited, Vs. Acit, Circle 1(1)(1), Naroda Road, Ahmedabad Ahmedabad-380025 [Pan : Aabca 2398 D]

For Appellant: Shri Biren Shah, AR &For Respondent: Shri Prathvi Raj Meena, CIT-DR &

Section 115JSection 143(3)Section 14ASection 250

…tain deductions and benefits, which was based on facts and evidence already present in the Assessing Officer's records. The Assessing Officer did not allow such claim relying on the judgment of the Hon’ble Apex Court in the case of Goetze (India) Ltd. vs CIT, 284 ITR 323. The same reads as under:- “2. The question raised in this appeal relates to whether the appellant assessee could make a claim for deduction other than by filing a revised return. The assessment year in question was 1995-96. The return was filed on 30-11-1995, by the appellant for the assessment year in question. On 12- 1-1998, the appellant sou…

K 113 Kugalur Primary Agricultural Coop Credit Society, Kugalur, Gobi Tk vs. The Deputy Commissioner of Income Tax CPC, Bangalore

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 99/CHNY/2025[2018-19]Status: DisposedITAT Chennai02 Jul 2025AY 2018-19

Bench: Shri George George K

For Appellant: Ms. R. Reshma, AdvocateFor Respondent: Shri Ashwin D Gowda, JCIT

Section 139(1)Section 143(1)Section 250Section 80Section 80PSection 80P(2)(a)

…tten submissions dated 07.05.2025 and 02.06.2025. The content of the same is that assessee had not made the claim of deduction u/s.80P of the Act and in light of the judgment of Hon’ble Apex Court in the case of Goetze (India) Ltd., vs. CIT reported in [2006] 284 ITR 323 (SC), the AO cannot entertain a new claim which is not made in the ROI. 7. I have heard rival submissions and perused the material on record. The assessee for the relevant assessment year 2018-19 had declared ‘nil’ income after claiming set-off of brought forward losses of Rs.2,37,001/-. The CPC processed the return filed :- 4 -: u/s.139(1) of t…

Jt. Cti (OSD), Circle-3(1)(1), Ahmedabad vs. M/S. Nirma Limited, Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 791/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 2(24)(x)Section 234BSection 271

…n case for the AY 2004-05. 30. However, the learned CIT(A) dismissed the additional ground of appeal of the assessee by observing as under: I have carefully considered the contention made by the appellant. Hon'ble Supreme Court in the case of Goetz India Ltd. 284 ITR 323 has held that any claim for deduction not made in the return cannot be made except by way of filing revised return. In the case of appellant , no revised return was filed for making the claim. Hence, the claim is not acceptable. The additional ground of appeal raised by appellant is dismissed. 31. Being aggrieved by the order of the learned CIT(A…

Nirma Limited, Ahmedabad vs. DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 516/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 2(24)(x)Section 234BSection 271

…n case for the AY 2004-05. 30. However, the learned CIT(A) dismissed the additional ground of appeal of the assessee by observing as under: I have carefully considered the contention made by the appellant. Hon'ble Supreme Court in the case of Goetz India Ltd. 284 ITR 323 has held that any claim for deduction not made in the return cannot be made except by way of filing revised return. In the case of appellant , no revised return was filed for making the claim. Hence, the claim is not acceptable. The additional ground of appeal raised by appellant is dismissed. 31. Being aggrieved by the order of the learned CIT(A…

The DCIT, Cir-3(1)(1), Ahmedabad vs. M/S. Nirma Limited, Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2224/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 2(24)(x)Section 234BSection 271

…n case for the AY 2004-05. 30. However, the learned CIT(A) dismissed the additional ground of appeal of the assessee by observing as under: I have carefully considered the contention made by the appellant. Hon'ble Supreme Court in the case of Goetz India Ltd. 284 ITR 323 has held that any claim for deduction not made in the return cannot be made except by way of filing revised return. In the case of appellant , no revised return was filed for making the claim. Hence, the claim is not acceptable. The additional ground of appeal raised by appellant is dismissed. 31. Being aggrieved by the order of the learned CIT(A…

M/S. Nirma Limited, Ahmedabad vs. The DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2008/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 2(24)(x)Section 234BSection 271

…n case for the AY 2004-05. 30. However, the learned CIT(A) dismissed the additional ground of appeal of the assessee by observing as under: I have carefully considered the contention made by the appellant. Hon'ble Supreme Court in the case of Goetz India Ltd. 284 ITR 323 has held that any claim for deduction not made in the return cannot be made except by way of filing revised return. In the case of appellant , no revised return was filed for making the claim. Hence, the claim is not acceptable. The additional ground of appeal raised by appellant is dismissed. 31. Being aggrieved by the order of the learned CIT(A…

M/S. Nirma Limited, Ahmedabad vs. The DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2007/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 2(24)(x)Section 234BSection 271

…n case for the AY 2004-05. 30. However, the learned CIT(A) dismissed the additional ground of appeal of the assessee by observing as under: I have carefully considered the contention made by the appellant. Hon'ble Supreme Court in the case of Goetz India Ltd. 284 ITR 323 has held that any claim for deduction not made in the return cannot be made except by way of filing revised return. In the case of appellant, no revised return was filed for making the claim. Hence, the claim is not acceptable. The additional ground of appeal raised by appellant is dismissed. 31. Being aggrieved by the order of the learned CIT(A)…

Pokharna Educational Trust, Pune vs. CIT (Exemption), Pune

In the result, appeal of the assessee is dismissed

ITA 1244/PUN/2025[2020-21]Status: DisposedITAT Pune30 Jun 2025AY 2020-21

Section 10Section 10(23)Section 10(230)(iad)Section 12ASection 143(3)Section 263Section 57

…he assessee only claimed the exemption during assessment proceedings and not in the return of income is factually incorrect and contrary to the record. The reliance placed by the PCIT on the decision of the Hon'ble Supreme Court in Goetze (India) Ltd. v. CIT (284 ITR 323) is also misplaced. In that case, the Hon'ble Court held that a claim not made in the return of income cannot be entertained by the AO unless a revised return is filed. However, in the present case, since the claim was made in the original return itself, the said ruling has no application whatsoever. Furthermore, Goetze (India) Ltd. does not curt…

Income Tax Officer, Ward-7(2)(1), Bengaluru, Bangalore vs. M/S. Bangalore Credit Co-Operative Society Limited, Bangalore

ITA 2348/BANG/2024[2020-21]Status: DisposedITAT Bangalore30 Jun 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Smt. Neha Sahay, D.R

…of the assessee is a fresh claim, it is settled law that a fresh claim can be made before the authorities during the proceedings pending before them for the relevant assessment year. The assessee relied on the decision of Hon’ble Supreme court in Goetze India 284 ITR 323 for the above proposition. 13.8 The AO disallowed the deduction u/s 80P(2)(d) of the Act. It is submitted that the investments were made out of surplus funds and relied on the decision of Hon’ble Karnataka High Court in the decision of PCIT v. Totagars Co-operative Sale Society 392 ITR 74 wherein it was held that the interest earned on deposits i…

Income-Tax Officer, Ward-7(2)(1), Bengaluru vs. M/S. Bangalore Credit Co-Operative Society Limited, Bengaluru

ITA 2347/BANG/2024[2018-19]Status: DisposedITAT Bangalore30 Jun 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Sri Sandeep Chalapathy, A.R

Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…of the assessee is a fresh claim, it is settled law that a fresh claim can be made before the authorities during the proceedings pending before them for the relevant assessment year. The assessee relied on the decision of Hon'ble Supreme court in Goetze India 284 ITR 323 for the above proposition. 13.8 The AO disallowed the deduction u/s 80P(2)(d) of the Act. It is submitted that the investments were made out of surplus funds and relied on the decision of Hon'ble Karnataka High Court in the decision of PCIT v. Totagars Co-operative Sale Society 392 ITR 74 wherein it was held that the interest earned on deposits…

Gangunaidu Sabbavarapu, Visakhapatnam vs. Income Tax Officer, Ward-2(5), Visakhpatnam

ITA 177/VIZ/2025[2023-24]Status: DisposedITAT Visakhapatnam27 Jun 2025AY 2023-24

Section 10(37)Section 139(1)Section 143(1)Section 2(37)Section 250Section 254Section 96

…of the subject land as exempt was by filing a revised return of income, but he had failed to avail the same. The Ld. DR to buttress her aforesaid contention relied on the judgment of the Hon'ble Supreme Court in the case of Goetze (India) Ltd. Vs. CIT [(2006) 284 ITR 323 (SC)]. The Ld. DR submitted that as the A.O. was not vested with any jurisdiction to allow a claim not raised by the assessee in his return of income, thus no infirmity could be attributed to him for re-quantifying the Long Term Capital Gains (“LTCG) on the compulsory acquisition of the subject land which the assessee himself had offered for tax…

Kerala State Warehousing Corporation, Ernakulam vs. DCIT Corporate Cir 1(1), Kochi

In the result, appeal filed by the assessee is partly allowed

ITA 73/COCH/2025[2017-18]Status: DisposedITAT Cochin26 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2017-18 Kerala State Warehousing Corporation .......... Appellant Mg Road, Ernakulam, Kerala-682016. Pan: Aabck1583G Vs. Deputy Commissioner Of Income Tax, .......... Respondent Corporate Circle-1(1), Central Revenue Building, Is Press Road, Kacheripady, Ernakulam, Kerala – 682018. Appellant By: Sri Harikrishnanunny, Ca Respondent By: Smt. Leena Lal, Sr. D.R.

For Appellant: Sri Harikrishnanunny, CAFor Respondent: Smt. Leena Lal, Sr. D.R

…losses for the AYs 2014- 15, 2015-16 and 2016-17. While doing so, the AO refused to take the cognizance of revised computation of income, audit report and placing reliance on the decision of the Hon'ble Supreme Court in the case of Goetze (India) Ltd vs. CIT (284 ITR 323) for the purpose of computation of total income. 2. Being aggrieved by the above order of the AO, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action of the AO by holding that in view of the decision of the Hon'ble Supreme Court in the case of Goetze (India) Ltd vs. CIT (supra) an assessee cannot amend a retur…

Gramin Janatha Welfare Co-Operative Society Ltd.No R 1224, Kallur vs. Income Tax Officer, Ward 1(1), Thrissur

In the result, appeal filed by the assessee is allowed

ITA 285/COCH/2025[2023-24]Status: DisposedITAT Cochin23 Jun 2025AY 2023-24

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadavassessmentyear:2023-24

For Appellant: Shri Amaljith P.J., A.RFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(1)Section 80PSection 80P(2)

…ITA No.285/Coch/2025 GraminJanatha Welfare Co-operative Society Ltd., Thrisuur IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH:COCHIN BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI PRAKASH CHAND YADAV, JUDICIAL MEMBER AssessmentYear:2023-24 GraminJanatha Welfare Co-operative Society Ltd Kallur PO ITO Kallur Ward 1(1) Vs. Thrissur 680 317 Thrissur Kerala PAN NO : AAGAG7408P APPELLANT RESPONDENT Appellant by : Shri Amaljith P.J., A.R. Respondent by : Smt. Leena Lal, Sr. D.R. Date of Hearing : 29.05.2025 Date of Pronouncement : 23.06.2025 O R D E R PERPRAKASH CHAND YADAV, JUDICIAL MEMBER: Present…