Assistant Commissioner of Income Tax, Central Circle -2, Surat vs. M/S Aalidhar Textool Engineers Pvt. Ltd., Surat
In the result, the grounds of appeal raised by Revenue are partly allowed
ITA 226/SRT/2023[2017-18]Status: DisposedITAT Surat20 Nov 2023AY 2017-18
Bench: Shri Pawan Singh & Dr. Arjun Lal Saini
Section 133(6)Section 14ASection 254(1)Section 80G
…Rule 8D was not applicable, the Assessing Officer was required to adopt reasonable method in consistent with the facts and circumstances and material on record. We find that Hon’ble Apex Court in Madras Co-Operative Central Land Mortgage Bank Limited vs. CIT, 67 ITR 89 (SC) also held that where the income of cooperative society from its trading activity was exempt from tax, the income of assessee from government securities was apportioned between income earned from investment for trading and non-trading purposes. Thus, we find that in absence of a statutory rule or a departmental instruction, the Hon’ble Apex Cou…