KHAREL VIBHAG V. V. K.S. M. LIMITED,NA vs. ARIVS.THE INCOME TAX OFFICER, WARD-2, NAVSARI

In the result, appeals filed by the assessees (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.173/Srt/2017 & 199/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) M/S.Maroli Bazar Vibhag Vividh Vs. The Income Tax Officer, Ks.M.L. Ward-2, Navsari. At & Post – Maroli Bazar, Tal-Jalalpore, Dist-Navsari. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam 1095 J (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.200/Srt/2018 & 201/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) Kharel Vibhag V.V.K.S.M. Ltd., Vs. The Deputy Commissioner Of Income At & Post – Kharel, Tax, Navsari. Navsari. & The Income Tax Officer, Ward-2, Navsari.

B : Deduction in respect of certain payments (sections 80C to 80GGC) C : Deductions in respect of certain incomes (sections 80H to 80TT) D : Other deductions (sections 80U to 80VV) Section 80A(1) of the Act provides that in computing total income of an assessee, there shall be allowed from the gross total income, the deductions specified in sections

KHAREL VIBHAG VIVIDH KARYAKARI SAHKARI MANDLI LTD.,NA vs. ARIVS.THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE NAVSARI, NAVSARI

In the result, appeals filed by the assessees (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.173/Srt/2017 & 199/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) M/S.Maroli Bazar Vibhag Vividh Vs. The Income Tax Officer, Ks.M.L. Ward-2, Navsari. At & Post – Maroli Bazar, Tal-Jalalpore, Dist-Navsari. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam 1095 J (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.200/Srt/2018 & 201/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) Kharel Vibhag V.V.K.S.M. Ltd., Vs. The Deputy Commissioner Of Income At & Post – Kharel, Tax, Navsari. Navsari. & The Income Tax Officer, Ward-2, Navsari.

B : Deduction in respect of certain payments (sections 80C to 80GGC) C : Deductions in respect of certain incomes (sections 80H to 80TT) D : Other deductions (sections 80U to 80VV) Section 80A(1) of the Act provides that in computing total income of an assessee, there shall be allowed from the gross total income, the deductions specified in sections

M/S. MAROLI BAZAR VIBHAG VIVIDH KARYAKARI SAHKARI MANDLI LTD.,,NA vs. ARIVS.DEPUTY COMMISSIONER OF INCOME TAX, NAVSARI CIRCLE , NAVSARI

In the result, appeals filed by the assessees (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.173/Srt/2017 & 199/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) M/S.Maroli Bazar Vibhag Vividh Vs. The Income Tax Officer, Ks.M.L. Ward-2, Navsari. At & Post – Maroli Bazar, Tal-Jalalpore, Dist-Navsari. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam 1095 J (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.200/Srt/2018 & 201/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) Kharel Vibhag V.V.K.S.M. Ltd., Vs. The Deputy Commissioner Of Income At & Post – Kharel, Tax, Navsari. Navsari. & The Income Tax Officer, Ward-2, Navsari.

B : Deduction in respect of certain payments (sections 80C to 80GGC) C : Deductions in respect of certain incomes (sections 80H to 80TT) D : Other deductions (sections 80U to 80VV) Section 80A(1) of the Act provides that in computing total income of an assessee, there shall be allowed from the gross total income, the deductions specified in sections

SHRI NEHRUNAGAR CO. OP HOUSING SOCIETY,SURAT vs. INCOME TAX OFFICER, WARD-1(3)(5), SURAT

In the result, the grounds of appeal raised by the assessee are allowed

Bench: Dr. A. L. Sainiआयकर अपील सं./Ita No.478/Srt/2023 Assessment Year: (2017-18) (Physical Hearing) Shri Nehrunagar Co.Op. Housing Vs. The Ito, Society, Ward – 1(3)(5), Umang Hall, Nehrunagar Society, Surat Ichchanath Road, Surat – 395007. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabas2271H (Appellant) (Respondent)

b) (either independently of, or in addition to, all or any of the activities so specified), so much of its profits and gains attributable to such activities as does not exceed,— (i) where such co-operative society is a consumers' co-operative society, one hundred thousand rupees; and (ii) in any other case, fifty thousand rupees. Explanation.—In this clause

M/S. BARDOLI VIBHAG GRAM VIKAS CO.-OP.CREDIT SOCIETY LTD.,,SURAT vs. THE PR.. COMMISSIONER OF INCOME TAX, -2, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing) आ.अ.सं./I.T.A No.283/Srt/2019 "नधा"रण वष"/Assessment Year: 2014-15 Bardoli Vibhag Gram Vikas Co.Op. Vs The Principal Credit Society Ltd., Commissioner Of Income Sahakar Sadan, Station Road, Tax-2, Surat. Bardoli, Surat. [Pan: Aaatb 8135 B] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओर से /Assessee By Shri Mitesh Modi – Ca राज"वक"ओर से /Revenue By Shri Ritesh Mishra – Cit-Dr सुनवाई की तारीख/ Date Of Hearing: 29.04.2021 उ"घोषणा क" तार"ख/Pronouncement On: 12.05.2021 आदेश /O R D E R Per Pawan Singh, Judicial Memeber: 1. This Appeal By The Assessee Is Directed Against The Order Of Ld. Principal Commissioner Of Income Tax-2, Surat Hereinafter Referred As “Ld. Pcit”, Passed Under Section 263 Of Income- Tax Act (Act) Dated 26.03.2019 For The Assessment Year (Ay) 2014-15. 2. Brief Facts Of The Case Are That The Assessee Is A Co-Operative Society Engaged In The Business Of Providing Credit Facility To Its Members By Accepting The Deposits From Members & Lending Money Them Too. The Assessee Filed Its Return Of Income For A.Y. 2014-15 On 21.08.2013 Declaring Nil Income. In The Computation Of Income, The Assessee Claimed Deduction 80P Of The Act Of Rs.7,03,56,728/-. The Return Of Income Was Bardoli Vibhag Gram Vikas Cooperative Credit Society Ltd., Vs. Pcit

b) of Explanation 2 of section 263 is also applicable in the present case. 5. The assessee filed its reply to the show cause vide its reply dated 17.03.2019. The contents reply of assessee is extracted by ld. PCIT in its order. In the reply, the assessee stated that the assessee has claimed deduction under section 80P(2

SHREE MADHI VIBHAG KHAND UDYOG SAHAKARI MANDLI LTD.,BARDOLI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX -1, SURAT

In the result, the grounds of appeal raised by the assessee are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Shree Madhi Vibhag Khand Udyog Pr.C.I.T.-1 Sahakari Mandli Ltd., Room No. 123, 1St Floor, Vs. P.O. Box No. 5, At & Post- Madhi, Aayakar Bhavan, Tal: Bardoli, Surat-394340. Majuragate, Surat. Pan: Aaaas 4732 J Appellant Respondednt

b) of the Explanation 2 of Section 263 of the Act patently in violation of "rule of consistency" is bad in law, without jurisdiction, arbitrary, invalid and hence, liable to be quashed. 6. Your appellant further reserves its rights to add, alter, amend or modify any of the aforesaid grounds before or at the time of hearing of an appeal

THE GOVERNMENT E CO-OPERATIVE SOCIETY LTD.,,BHARUCH vs. PRINCIPAL COMMISSIONER OF INCOME TAX , VADODARA-1, VADODARA

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.126/Srt/2023 (Ay 2017-18) (Hearing In Virtual Court) The Government E Co- Principal Commissioner Of Operative Society Ltd./, Income Tax, Vadodara-1, Vs First Floor, Government Room No.214, 2Nd Floor, Sevasadan, Bhag-2, B/H Aaykar Bhawan, Race Course Pwd Office, Bharuch- Circle, Vadodara-390007 392001 Pan No. Aaalt 0832 D अपीलाथ"/Appellant ""थ" /Respondent

B. Koli, CIT-DR अपील पंजीकरण/Appeal instituted on 20.02.2023 सुनवाई की तारीख/Date of hearing 23.05.2023 उद्घोषणा की तारीख/Date of 23.05.2023 pronouncement Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of ld. Principal Commissioner of Income-tax-Valsad [for short

GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,,NA vs. ARIVS.INCOME TAX OFFICER WARD-2, NAVSARI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

B. The Learned Commissioner (Appeals) has confirmed the ratio calculated by the Learned assessing Officer but it is implemented wrongly by the Learned assessing Officer regarding the relief of section 80P(2)(a)(iv). We have provided the details fully. In fact, it is a mathematical mistake to be rectified will result into the deletion of Rs.33,66,477/- from

ASSISTANT COMMISSIONER OF INCOME TAX,, NA vs. ARIVS.GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,, NAVSARI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

B. The Learned Commissioner (Appeals) has confirmed the ratio calculated by the Learned assessing Officer but it is implemented wrongly by the Learned assessing Officer regarding the relief of section 80P(2)(a)(iv). We have provided the details fully. In fact, it is a mathematical mistake to be rectified will result into the deletion of Rs.33,66,477/- from

GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,,NA vs. ARIVS.INCOME TAX OFFICER WARD-2, NAVSARI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

B. The Learned Commissioner (Appeals) has confirmed the ratio calculated by the Learned assessing Officer but it is implemented wrongly by the Learned assessing Officer regarding the relief of section 80P(2)(a)(iv). We have provided the details fully. In fact, it is a mathematical mistake to be rectified will result into the deletion of Rs.33,66,477/- from

ASSISTANT COMMISSIONER OF INCOME TAX,, NA vs. ARIVS.GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,, NAVSARI

In the result, appeal filed by the assessee in ITA No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

B. The Learned Commissioner (Appeals) has confirmed the ratio calculated by the Learned assessing Officer but it is implemented wrongly by the Learned assessing Officer regarding the relief of section 80P(2)(a)(iv). We have provided the details fully. In fact, it is a mathematical mistake to be rectified will result into the deletion of Rs.33,66,477/- from

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

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

b) ITA No.3107/Del/2010 In the Income Tax Appellate Tribunal Delhi Bench : H : New Delhi ACIT, Haldwani, Uttarakhand Vs Udham Singh Nagar Distt. Co- operative bank ITA No. 3448/Del/2016 8. From the definition of the 'Recognized Provident Fund' in Section 2(38) of the Act, it is evident that there are two independent limbs of the definition, i.e. firstly, the approval/recognition

M/S SACHIN UDYOG NAGAR SAHKARI MANDLI LTD.,,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(2), SURAT

In the result, the appeal of the Revenue is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.438 & 439/Srt/2022 Assessment Years: (2017-18 & 2018-19) (Virtual Court Hearing) Sachin Udyog Nagar Sahkari Mandli Vs. The Acit, Circle -1(2), Ltd., Surat. 2Nd Floor, Vivekanand Chambers, Beside Rajehree Hall, Sangrampura, Surat – 395006. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacts7414C (Appellant) (Respondent) Assessee By Shri Kamlesh Bhatt, Ar Respondent By Shri Ashok B. Koli, Cit(Dr) & Vinod Kumar, Sr. Dr 07/02/2023 Date Of Hearing Date Of Pronouncement 07/02/2023 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Two Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2017-18 & 2018-19, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Surat [In Short “The Ld. Cit(A)”], Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

section doesn’t bar the deduction of interest received by cooperative society from a cooperative bank. The deduction was being allowed for several preceding assessment years in the case of the appellant society. The AR has referred to decisions of the 438 & 439/SRT/2022/AY.2017-18 & 2018-19 Sachin Udyog Nagar Sahkari Mandli Ltd. jurisdictional High Court and jurisdiction ITAT Benches wherein

THE ACIT, CIRCLE-6,, SURAT vs. BARDOLI VIBHAG GRAM VIKAS CO.OP.CREDIT SOCIETY LTD.,, SURAT

In the result, the appeal of the revenue is dismissed

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No.2582/Ahd/2014/Srt िनधा"रण वष"/Assessment Year : 2010-11 Assistant Commissioner Of Vs. Bardoli Vibhag Gram Vikas Co- Income Tax, Operative Credit Society Ltd., Circle –6, Surat – 395001. Sardar Baug Bardoli, District Surat, Surat – 396 420 [Pan: Aaatb 8135 B] अपीलाथ" Appellant ""यथ"/Respondent Shri Mitish S. Modi, Ca िनधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By Shri Arvind Kumar Singh, Sr.Dr 20-06-2018 सुनवाई क" तारीख/ Date Of Hearing: 28-06-2018 उ"ोषणा क" तारीख/Pronouncement On आदेश /O R D E R Per O. P. Meena, Accoutant Member:

B Interest and dividend from Rs.3,34,23,194/- other co-op. socieites. Total Rs.3,34,73,194/- 4. The AO further observed that the assessee earned gross interest income of Rs.4,45,74,034/- during the year under consideration. As per him whatever is accepted as deposits from the members by the assessee were given to the members

ASSISTANT COMMISSIONER OF INCOME -TAX, CIRCLE-1(1)(1),SURAT, MAJURA GATE,SURAT vs. SHREE ARADHNA URBAN CO OP CREDIT SOCIETY LTD, VARACHHA ROAD

In the result, this appeal of revenue is dismissed

Bench: Shri Pawan Singh(Hybrid Hearing) A.C.I.T., Shree Aradhna Urban Co Op Credit Circle-1(1)(1), Society Ltd., Vs. Surat. 128-129, Super Diamond Market, Varachha Road, Surat-395006. Pan No. Aaopc 8463 B Appellant/Revenue Respondent/Assessee

B Appellant/Revenue Respondent/Assessee Assessee represented by Shri Akshay Mitish Kumar Modi, C.A. Department represented by Shri Vinod Kumar, Sr. DR Appeal instituted on 24/07/2023 Date of hearing 28/11/2023 Date of pronouncement 28/11/2023 Order under Section 254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the Revenue is directed against the order of National Faceless

THE SURAT DISTRICT CO-OP. BANK LTD,SURAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2), SURAT, SURAT

In the result, ground No.6 raised by the assessee, is allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.590/Srt/2019 Assessment Year: (2011-12) (Physical Hearing) The Surat District Co.Op. Bank Ltd., Vs. The Acit, Circle-2(2), Shri Pramodbhai Desai Sahakar Bhavan, Surat. J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent) आयकर अपील सं./Ita No.4/Srt/2020 Assessment Year: (2011-12) The Dcit, Circle-2(2), Vs. The Surat District Co.Op. Bank Ltd., Surat. Shri Pramodbhai Desai Sahakar Bhavan, J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent)

80P ;' 16. We find that the assessee made a provision under section 36(1)(viia) of Rs. 7.16 Crore, the assessing Officer disallowed the claim to the extent of Rs.3.66 crores out of total claim of assessee under section 36(1)(viia) by taking view that the aforesaid amount under four heads are not provision for bad and doubtful debts

DCIT, CIRCLE-2(2), SURAT vs. THE SURAT DISTRICT CO-OP. BANK LIMITED, SURAT

In the result, ground No.6 raised by the assessee, is allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.590/Srt/2019 Assessment Year: (2011-12) (Physical Hearing) The Surat District Co.Op. Bank Ltd., Vs. The Acit, Circle-2(2), Shri Pramodbhai Desai Sahakar Bhavan, Surat. J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent) आयकर अपील सं./Ita No.4/Srt/2020 Assessment Year: (2011-12) The Dcit, Circle-2(2), Vs. The Surat District Co.Op. Bank Ltd., Surat. Shri Pramodbhai Desai Sahakar Bhavan, J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent)

80P ;' 16. We find that the assessee made a provision under section 36(1)(viia) of Rs. 7.16 Crore, the assessing Officer disallowed the claim to the extent of Rs.3.66 crores out of total claim of assessee under section 36(1)(viia) by taking view that the aforesaid amount under four heads are not provision for bad and doubtful debts

SHRAMDEEP URBAN CO OP. CREDIT SO. LTD.,SURAT vs. ACIT CIRCLE-3(3), SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.892/Srt/2024 Assessment Year: (2017-18) (Physical Hearing) Shramdeep Urban Co-Operative Credit Vs. The Acit, Society Limited, Circle -3(3), 11-12, Harekrushna Shopping Complex, Surat Varachha Road, Varachha, Surat - 395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaas3229C (Appellant) (Respondent) Appellant By Shri Rushi Parekh, Ar Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 30/12/2024 Date Of Pronouncement 03/02/2025

disallowance of deduction u/s 80P(2)(d)(i) of Rs.2,95,564/- being identical income of locker rent received by providing locker facility to member only and holding the same to be not income from business of banking as the assessee society is not holding banking license to operate locker. 2. Alternative, CIT(A) could have granted the deduction

AMALSAD VIBHAG VIVISH KARYAKARI SAHKARI KHEDUT MANDLI LTD.,NA vs. ARIVS.PCIT, VALSAD

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.491/Srt/2024 Ays: 2018-19 (Physical Court Hearing) Amalsad Vibhag Vividh Principal Commissioner Of Karyakari Sahkari Khedut Income Tax, Valsad, 301/3Rd Vs. Mandli Ltd., At & Po. Floor, Palak Arcade, Shanti Amalsad, Tal. Gandevi, Nagar, Tithal Road, Valsad-396 Dist. Navsari-396 310 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaaa 1043 N (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri P.M Jagasheth, Ca राज" की ओर से /Revenue By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 17.12.2024 उद्घोषणा की तारीख/Date Of Pronouncement 03.02.2025

disallowing the said deduction u/s 57 of the Act. The Ld. PCIT also addressed the issue with regard to assessee's argument about the reliance on ITAT rulings instead of jurisdictional High Court or Supreme Court decisions. The Ld. PCIT clarified that while the judgments referred to were from the ITAT, the said judgments had cited the relevant decisions from