In the result, both the appeal of the assessee and the Revenue are disposed off with above directions
Capital Loan 139,94,00,000/- -Over Draft 72,91,44,659/- -NDDB Loan 20,93,125/- -DCS 61,24,07,075/- Total Loan 274,30,44,859/- 274,30,44,859/- Investment in Stock and debtors -Sundry Debtors 122,01,11,586/- -Stock in trade 197,93,97,019/- Ms Jaipur Zila Dugdh Utpadak Sahakari Sangh Ltd., vs. DCIT