Totgars Co-operative Sale Society Ltd. v. ITO

322 ITR 283Supreme Court of India2010#33 most cited

What is Totgars Co-operative Sale Society Ltd. v. ITO authority for?

The interest income earned by a cooperative society from investing its surplus funds in fixed deposits with banks is not "derived from" its eligible business activities and is taxable as "income from other sources" under Section 56, thus not qualifying for deduction under Section 80P.

1,283

judgments rely on this decision, according to BharatTax’s citation analysis of 383,853 Indian tax judgments — from 2014 to 2026.

Also referred to as

Totgars Co-operative Sale Society · 322 ITR 283 · Section 80P · Section 80P(2)(d) · Section 80P(2)(a)(i) · interest income cooperative society · fixed deposit interest deduction · income from other sources Section 56 · derived from business · surplus funds investment

Also reported as

188 Taxmann.com 282

Sections most often in play

Section 80P(2)(d)Section 80P(2)(a)(i)Section 143(3)Section 80PSection 80P(4)Section 250Section 56Section 263

Issues it is cited on

section 80(2)(d)section 80p(2)(a)(iii)section 80p(4)section 2(19)section 80p(1)section 80p(2)(c)section 80(p)(2)(d)section 5(b)section 80p(2)(d)section 80p(2)(a)section 194a(3)(v)section 80p(2)(a)(i)

Judgments citing Totgars Co-operative Sale Society Ltd. v. ITO

Rayat Seva Krushi Udyog Sahakari Sangh Ltd, Kolhapur vs. Income-Tax Officer, Ward - 1(2), Kolhapur

In the result, all the three appeals are allowed

ITA 2145/PUN/2017[2012-13]Status: DisposedITAT Pune14 Nov 2018AY 2012-13

Bench: Shri R.S. Syal

Section 234ASection 56Section 80PSection 80P(2)(a)

…ssion”. Negating such opinion, the AO treated interest Sahakari Sangh Ltd., income as arising under the head “Income from other sources”. Relying on the judgment of Hon’ble Supreme Court in the case of Totgar’s Cooperative Sale Society Ltd. Vs. ITO (2010) 322 ITR 283 (SC), the AO denied the benefit of deduction on such interest income. Facts and circumstances of the other two years in appeal are similar except with the difference in the amounts of interest earned by the assessee from the respective FDRs maintained with State Bank of India. The ld. CIT(A) echoed the assessment orders on this issue, against wh…

Sugar Cane Producers Vividha Karyakari Sah. Society Ltd, Solapur vs. Income-Tax Officer, Ward - 1(4), Pandharpur

In the result, the appeal is allowed

ITA 3101/PUN/2017[2014-15]Status: DisposedITAT Pune13 Nov 2018AY 2014-15

Bench: Shri R.S. Syal

Section 80P

…terest income earned from investments in Fixed Deposits. A copy of such order has been placed on record. The tribunal has passed the order after considering the judgment of Hon’ble Supreme Court in the case of Totgar’s Cooperative Sale Society Ltd. VS. ITO 322 ITR 283 (SC). The ld. Departmental Representative fairly admitted that the facts and circumstances of the instant appeal are mutatis mutandis similar to those of 3 Sugar Cane Producers Vividha Karyakari Sah. Society Ltd., preceding years. Respectfully following the view taken by the Tribunal in assessee’s own case for the immediately preceding assessm…

Yashwantbhau Patil Gramin Bigersheti Sahakari Patsanstha Ltd, Solapur vs. Income-Tax Officer, Ward - 2, Pandharpur

In the result, the appeal is allowed

ITA 2107/PUN/2017[2013-14]Status: DisposedITAT Pune13 Nov 2018AY 2013-14

Bench: Shri R.S. Syal

Section 234BSection 80P

…on interest income earned from investments in Fixed Deposits. A copy of the order has been placed on record. Such decision has been taken after considering the judgment of Hon’ble Supreme Court in the case of Totgar’s Cooperative Sale Society Ltd. VS. ITO 322 ITR 283 (SC). The ld. Departmental Representative fairly admitted that the facts and circumstances of the instant appeal are mutatis mutandis similar to those of preceding year. Respectfully following the view taken by the Tribunal in assessee’s own case for the immediately preceding assessment year, I overturn the impugned order on this score and or…

Income-Tax Officer vs. Tata Motors Karamchari Sahakari Patpedhi Ltd, Pune

In the result, the appeal is dismissed

ITA 2596/PUN/2016[2012-13]Status: DisposedITAT Pune02 Nov 2018AY 2012-13

Bench: Shri R.S. Syal & Shri Vikas Awasthy, Jm

For Appellant: Shri K. SrinivasanFor Respondent: Shri Sudendhu Das
Section 80PSection 80P(2)(A)

…ssment year 2012-13. 2. The only issue in this appeal is against granting deduction u/s. 80P(2)(A)(i) of the Income-tax Act, 1961 (hereinafter also called as ‘the Act’) despite the judgment of the Hon’ble Supreme Court in Totgar’s Co-operative Society vs. ITO 322 ITR 283. 3. Briefly stated, the facts of the case are that the assessee is a Co-operative Society registered under Maharashtra Co-operative Societies Act, 1960. It is engaged in providing credit facilities to its members and the main activity of the society is to disburse and recover loans to/from its members. The members of the society are permanent emp…

Chandraprabhu Gramin Bigar Sheti Sahakari Pat Santha Maryadit, Solapur vs. Income-Tax Officer, Ward - 1(4), Pandharpur

In the result, the appeal of the revenue stands dismissed

ITA 2542/PUN/2017[2012-13]Status: DisposedITAT Pune26 Oct 2018AY 2012-13

Bench: Shri Anil Chaturvedi, Am

For Appellant: Ms. Riya S. ShahFor Respondent: Mrs. Shabana Parveen
Section 143(3)Section 56Section 80P(2)(a)

…आयकर अपील"य अ"धकरण] पुणे "यायपीठ “एक सद"य” पुणे म" IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI ANIL CHATURVEDI, AM आयकर अपील सं. / ITA Nos.2427 & 2542/PUN/2017 "नधा"रण वष" / Assessment Year : 2013-14 & 2012-13 Chandraprabhu Gramin Bigar Sheti ………. अपीलाथ" / Sahkari Pat Santha Maryadit, Appellant A/p: Natepute, Tal Malshiras, Dist. Solapur. PAN : AAAAC2702L. बनाम v/s The Income Tax Officer, ………. ""यथ" / Ward – 1(4), Padharpur. Respondent Assessee by : Ms. Riya S. Shah. Revenue by : Mrs. Shabana Parveen. सुनवाई क" तार"ख / घोषणा क" तार"ख / Date of Hearing : 23.10.2018 Date of Pronounc…

Sugar Cane Producers Vividh Karyakari Sah. Society Ltd, Solapur vs. Income-Tax Officer, Ward - 1(4), Pandharpur

In the result, the appeal of the revenue stands dismissed

ITA 2538/PUN/2017[2013-14]Status: DisposedITAT Pune26 Oct 2018AY 2013-14

Bench: Shri Anil Chaturvedi, Am

For Appellant: Ms. Riya S. Shah & Shri S.N. DoshiFor Respondent: Mrs. Shabana Parveen
Section 143(3)Section 56Section 80P(2)(a)

…Central Bank of India, Malinagar, State Bank of India Akluj & Vainganga Bank as income from other sources and taxing the same under section 56 at the IT. Act 1961. 2. Learned CIT(A) erred in relying the decision of Todgars Co- operating Sale Society Lts. - sc-322 ITR 283 the facts of which are totally distinguishable. In case of Various Patsanstha cases Honourable Pune IT At Bench has disguised the decision of Todgar Co-perative Sale Society Ltd. SC stated that how it is not applicable to Patsanstha. Your Appellant Society is also engaged in carrying the main activity of Patsanstha only. 3. On the facts and in th…

Sugar Cane Producers Vividh Karyakari Sah. Society Ltd, Solapur vs. Income-Tax Officer, Ward - 1(4), Pandharpur

In the result, the appeal of the revenue stands dismissed

ITA 2537/PUN/2017[2012-13]Status: DisposedITAT Pune26 Oct 2018AY 2012-13

Bench: Shri Anil Chaturvedi, Am

For Appellant: Ms. Riya S. Shah & Shri S.N. DoshiFor Respondent: Mrs. Shabana Parveen
Section 143(3)Section 56Section 80P(2)(a)

…Central Bank of India, Malinagar, State Bank of India Akluj & Vainganga Bank as income from other sources and taxing the same under section 56 at the IT. Act 1961. 2. Learned CIT(A) erred in relying the decision of Todgars Co- operating Sale Society Lts. - sc-322 ITR 283 the facts of which are totally distinguishable. In case of Various Patsanstha cases Honourable Pune IT At Bench has disguised the decision of Todgar Co-perative Sale Society Ltd. SC stated that how it is not applicable to Patsanstha. Your Appellant Society is also engaged in carrying the main activity of Patsanstha only. 3. On the facts and in th…

Chandraprabhu Gramin Bigar Sheti Sahakari Pat Sanstha Maryadit, Solapur vs. Income-Tax Officer, Ward - 1(4), Pandharpur

In the result, the appeal of the revenue stands dismissed

ITA 2427/PUN/2017[2013-14]Status: DisposedITAT Pune26 Oct 2018AY 2013-14

Bench: Shri Anil Chaturvedi, Am

For Appellant: Ms. Riya S. ShahFor Respondent: Mrs. Shabana Parveen
Section 143(3)Section 56Section 80P(2)(a)

…आयकर अपील"य अ"धकरण] पुणे "यायपीठ “एक सद"य” पुणे म" IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI ANIL CHATURVEDI, AM आयकर अपील सं. / ITA Nos.2427 & 2542/PUN/2017 "नधा"रण वष" / Assessment Year : 2013-14 & 2012-13 Chandraprabhu Gramin Bigar Sheti ………. अपीलाथ" / Sahkari Pat Santha Maryadit, Appellant A/p: Natepute, Tal Malshiras, Dist. Solapur. PAN : AAAAC2702L. बनाम v/s The Income Tax Officer, ………. ""यथ" / Ward – 1(4), Padharpur. Respondent Assessee by : Ms. Riya S. Shah. Revenue by : Mrs. Shabana Parveen. सुनवाई क" तार"ख / घोषणा क" तार"ख / Date of Hearing : 23.10.2018 Date of Pronounc…

Gujarat State Co. Op. Fruit and Vegetable Marketing Federation Ltd., Surat vs. The Dy. Commissioner of Income Tax, Circle-2(3), Surat

In the result, the appeal of the assessee stands allowed

ITA 2502/AHD/2016[2013-14]Status: DisposedITAT Surat08 Oct 2018AY 2013-14

Bench: C .M. Garg & O. P. Meenaआ.अ.सं./I.T.A No.2502/Ahd/2016/Srt िनधा"रण वष"/Assessment Year:2013-14 Gujarat State Co-Op. Fruit & V. Deputy Commissioner Of Vegetable Marketing Federation Income-Tax, Ltd. , 43 Sardar Baug Bardoli Circle – 2(3), Surat 394602 Surat Pan:Aaag0983H अपीलाथ" Appellant ""यथ"/Respondent Shri Shailesh Vaidya, Ca िनधा"रती क" ओर से Assessee By Shri Vinod Kumar, Sr. D.R. राज"व क" ओर से Revenue By 31.10.2018 सुनवाई क" तारीख Date Of Hearing 01.11.2018 उ"ोषणा क" तारीख Date Of Pronouncement आदेश /Order Per O. P. Meena, Am 1. This Appeal At The Instance Of The Assessee Is Directed Against An Order Dated 30.08.2016 Passed By Learned Commissioner Of Income Tax (Appeals)-1,Surat (In Short “The Cit (A)”) For The Assessment Year 2013- 14. 2. Ground No. 1 States That The Ld. Cit (A) Erred In Confirming The Action Of The Ao In Not Granting The Claim Of Deduction Of Rs. 2,45,017 On Account Of Provident Fund. 3. Brief Facts Are That During The Course Of Assessment Proceedings, The Assessee Submitted A Revised Computation Of Total Income Stating The Gujarat State Co-Op. Fruit & Vegetable Marketing Federation Ltd.-2502-Ahd/2016-A.Y. 13-14 V. Dcit2(3) Surat Page 2 Of 11

Section 2Section 2(38)Section 36(1)(iv)Section 38

…hat the appellant has accepted interest income of Rs. 3,43,524 is taxable income as income from other source and not as business income. Thus, the appellant unconditionally accepted the applicability of ratio of Totagars Co-operative Sales Society Ltd. v. ITO 322 ITR 283 (SC) that income is taxable as income from other source and not as business income and such income is not eligible for deduction under section 80P(2)(a)(i) of the Act . Thus, there is no denying fact that interest income of Rs. 3,43,524 is taxable under the head income from other source and not eligible for deduction under section 80P(2)(a)(i).Ag…

M/S. Hinglajmata Nagari Sahakari Sanstha Maryadit, Solapur vs. Income-Tax Officer, Ward - 2(4), Solapur

ITA 2062/PUN/2017[2013-14]Status: DisposedITAT Pune05 Oct 2018AY 2013-14

Bench: Shri D. Karunakara Rao, Am आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं. / Ita No.2062/Pun/2017 अपील िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष" / Assessment Year : 2013-14 वष"

For Appellant: Shri Pramod ShingteFor Respondent: Shri Sanjeev Ghei
Section 143(3)Section 80PSection 80P(2)(a)

…ramin Bigarsheti Sah. Patsanstha Vs. ITO (supra) and in the case of Baliraja Gramin Bigarsheti Vs. ITO in ITA Nos. 50 & 51/PUN/2017, dated 26-03-2018 where the judgments of Hon’ble Supreme Court in the case of Totgars Co-operative Sale Society Ltd. Vs. ITO 322 ITR 283 and Hon’ble Delhi High Court in the case of Mantola Co-operative Thrift & Credit Society Ltd Vs. CIT 50 taxmann.com 278 (Delhi) are considered. I find it relevant to extract the findings of the Tribunal in the case of Vijay Gramin Bigarsheti Sah. Patsanstha Vs. ITO (supra) and the same are reproduced here as under : “9. On hearing both the pa…

The ITO, WD-3, Thiruvalla vs. M/S.Vazhoor Farmers Service Co-Op Bank Ltd, Kottayam

ITA 180/COCH/2018[2014-15]Status: DisposedITAT Cochin24 Sept 2018AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt. A.S.BindhuFor Respondent: Sri. Prasanth Srinivas
Section 56Section 80PSection 80P(2)(a)

…has not challenged the decision only because of low tax effect prescribed for filing further appeal in that case. 3. The Ld. CIT (A) ought to have considered the decision of Hon'ble SC in the case of Totgar's Co-operative Sale Society Ltd. (2010) reported in 322 ITR 283 where Hon'ble Supreme court was of the view that such interest income earned by assessee would come in category of 'income from other sources' taxable U/S 56 of the income tax act and would not quality for deduction as business income 80P (2)(i). 4. For these and other grounds that may be advanced at the time of hearing, the order of the learned…

Income Tax Officer vs. Shri Laxmi Narayan Nagari Sahakari Pat Sanstha, Kolhapur

In the result, the claim of the appellant u/s 80P(2)(a)(i) of the Act for the year under consideration is allowed

ITA 2827/PUN/2016[2013-14]Status: DisposedITAT Pune19 Sept 2018AY 2013-14

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील अपील संसंसंसं. / Ita No.2827/Pun/2016 आयकर आयकर आयकर अपील अपील िनधा"रण वष" वष" / Assessment Year : 2013-14 िनधा"रण िनधा"रण िनधा"रण वष" वष"

For Appellant: Shri Pankaj GargFor Respondent: None
Section 143(3)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…s of section 80P(2) (d) of the Income Tax Act, 1961? 2. Whether on the facts and in the circumstances of the case and in law, the Ld.CIT(A) was justified in distinguishing the Hon'ble Apex Court's decision in Totgars Co-op Sale Society Ltd Vs. ITO reported as 322 ITR 283 (SC), ignoring the clear provisions of section 80P(2) (d) of the Income Tax Act, 1961, wherein income by way of interest or dividend derived by Co- operative Society from its investment with any other Co-operative Society is eligible for deduction and not income by way of interest from banks other than Co-operative banks/societies? 3. The appella…

The ITO, WD-4, Thiruvalla vs. The Changanasserry North Service Co-Op Bank Ltd, Kottayam

ITA 192/COCH/2018[2013-14]Status: DisposedITAT Cochin18 Sept 2018AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: --- None ---For Respondent: Smt. A.S.Bindhu
Section 56Section 80PSection 80P(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Chandra Poojari, AM & Shri George George K, JM ITA No.189/Coch/2018 : Asst.Year 2014-2015 The Income Tax Officer, M/s.The Vakathanam Ward – 3 Vs. Service Co-operative Bank Thiruvalla. Limited,Vakathanam Changanachery Kottayam – 686 538. PAN : AABAV4696H. (Appellant) (Respondent) CO No.47/Coch/2018 : Asst.Year 2014-2015 M/s.The Vakathanam The Income Tax Officer, Service Co-operative Bank Vs. Ward – 3 Limited,Vakathanam Thiruvalla. Changanachery Kottayam – 686 538. (Cross Objector) (Respondent) Revenue by : Smt. A.S.Bindhu Assessee by : --- Non…

The ITO, WD-3, Thiruvalla vs. Vakathanam Service Co-Op Bank Ltd, Kottayam

ITA 189/COCH/2018[2013-14]Status: DisposedITAT Cochin18 Sept 2018AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: --- None ---For Respondent: Smt. A.S.Bindhu
Section 56Section 80PSection 80P(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Chandra Poojari, AM & Shri George George K, JM ITA No.189/Coch/2018 : Asst.Year 2014-2015 The Income Tax Officer, M/s.The Vakathanam Ward – 3 Vs. Service Co-operative Bank Thiruvalla. Limited,Vakathanam Changanachery Kottayam – 686 538. PAN : AABAV4696H. (Appellant) (Respondent) CO No.47/Coch/2018 : Asst.Year 2014-2015 M/s.The Vakathanam The Income Tax Officer, Service Co-operative Bank Vs. Ward – 3 Limited,Vakathanam Thiruvalla. Changanachery Kottayam – 686 538. (Cross Objector) (Respondent) Revenue by : Smt. A.S.Bindhu Assessee by : --- Non…

The ITO, WD-1, Alappuzha vs. M/S.Alappuzha Govt.Servants Co-Op Bank Ltd, Alappuzha

ITA 188/COCH/2018[2014-15]Status: DisposedITAT Cochin18 Sept 2018AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt. A.S.BindhuFor Respondent: --- None ---
Section 56Section 80PSection 80P(2)(a)

…has not challenged the decision only because of low tax effect prescribed for filing further appeal in that case. 3. The Ld. CIT (A) ought to have considered the decision of Hon'ble SC in the case of Totgar's Co-operative Sale Society Ltd. (2010) reported in 322 ITR 283 where Hon'ble Supreme court was of the view that such interest income earned by assessee would come in category of 'income from other sources' taxable U/S 56 of the income tax act and would not quality for deduction as business income 80P (2)(i). 4. The Ld. CIT (A) ought to have noticed that, in a communication received from the office of the PCC…

The ITO, WD-1, Alappuzha vs. M/S.Alappuzha Govt.Servants Co-Op Bank Ltd, Alappuzha

ITA 187/COCH/2018[2013-14]Status: DisposedITAT Cochin18 Sept 2018AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt. A.S.BindhuFor Respondent: --- None ---
Section 56Section 80PSection 80P(2)(a)

…has not challenged the decision only because of low tax effect prescribed for filing further appeal in that case. 3. The Ld. CIT (A) ought to have considered the decision of Hon'ble SC in the case of Totgar's Co-operative Sale Society Ltd. (2010) reported in 322 ITR 283 where Hon'ble Supreme court was of the view that such interest income earned by assessee would come in category of 'income from other sources' taxable U/S 56 of the income tax act and would not quality for deduction as business income 80P (2)(i). 4. The Ld. CIT (A) ought to have noticed that, in a communication received from the office of the PCC…

The ITO, Alappuzha vs. M/S.Cherthala Government Servants Co-Op Bank Ltd, Alappuzha

ITA 186/COCH/2018[2014-15]Status: DisposedITAT Cochin18 Sept 2018AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt. A.S.BindhuFor Respondent: --- None ---
Section 56Section 80PSection 80P(2)(a)

…has not challenged the decision only because of low tax effect prescribed for filing further appeal in that case. 3. The Ld. CIT (A) ought to have considered the decision of Hon'ble SC in the case of Totgar's Co-operative Sale Society Ltd. (2010) reported in 322 ITR 283 where Hon'ble Supreme court was of the view that such interest income earned by assessee would come in category of 'income from other sources' taxable U/S 56 of the income tax act and would not quality for deduction as business income 80P (2)(i). 4. The Ld. CIT (A) ought to have noticed that, in a communication received from the office of the PCC…

The ITO, WD-3, Alappuzha vs. The Parayakkad Service Co-Op Bank Ltd, Alappuzha

ITA 185/COCH/2018[2014-15]Status: DisposedITAT Cochin18 Sept 2018AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt. A.S.BindhuFor Respondent: --- None ---
Section 56Section 80PSection 80P(2)(a)

…has not challenged the decision only because of low tax effect prescribed for filing further appeal in that case. 3. The Ld. CIT (A) ought to have considered the decision of Hon'ble SC in the case of Totgar's Co-operative Sale Society Ltd. (2010) reported in 322 ITR 283 where Hon'ble Supreme court was of the view that such interest income earned by assessee would come in category of 'income from other sources' taxable U/S 56 of the income tax act and would not quality for deduction as business income 80P (2)(i). 4. The Ld. CIT (A) ought to have noticed that, in a communication received from the office of the PCC…

The ITO, WD-5, Thiruvalla vs. M/S.the Ithithanam Janatha Service Co-Op Bank Ltd, Changanacherry

ITA 181/COCH/2018[2013-14]Status: DisposedITAT Cochin18 Sept 2018AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt. A.S.BindhuFor Respondent: --- None ---
Section 56Section 80PSection 80P(2)(a)

…has not challenged the decision only because of low tax effect prescribed for filing further appeal in that case. 3. The Ld. CIT (A) ought to have considered the decision of Hon'ble SC in the case of Totgar's Co-operative Sale Society Ltd. (2010) reported in 322 ITR 283 where Hon'ble Supreme court was of the view that such interest income earned by assessee would come in category of 'income from other sources' taxable U/S 56 of the income tax act and would not quality for deduction as business income 80P (2)(i). 4. The Ld. CIT (A) ought to have noticed that, in a communication received from the office of the PCC…

The Veer Co-Operative Group Housing Society Ltd., New Delhi vs. ITO, Ward- 39(4), New Delhi

In the result, ITA.No.2787/Del

ITA 2788/DEL/2018[2014-15]Status: DisposedITAT Delhi04 Sept 2018AY 2014-15

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Ms. Mansi JainFor Respondent: Shri Vijay Kumar Jiwani, Sr. D.R
Section 80P(2)(c)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘C+SMC’, NEW DELHI BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER ITA.Nos.2787 & 2788/Del/2018 Assessment Years 2013-2014 & 2014-2015 M/s. The Veer Cooperative The Income Tax Officer, Group Housing Society vs. Ward-39(4), Limited, Plot No.28, Sector-13, Rohini, New Delhi-110085. New Delhi. PAN AAAAT6615K Appellant Respondent Shri Rano Jain, Mr. Pranshy Singhal & Assessee by : Ms. Mansi Jain Advocates Revenue by : Shri Vijay Kumar Jiwani, Sr. D.R. Date of Hearing : 09.08.2018 Date of Pronouncement : 04 .09.2018 2…