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2014 (1) TMI 1080 - ITAT COCHINDeduction u/s 80P(2)(a)(vi) - Held that:- The societies have only used the labour of its members in tapping toddy, a naturally available product as all the members were toddy tapping workers - These societies have only generated employment opportunities to its members and they have paid wages to its member-workers in proportion to the quantity of toddy tapped by each of the members - These societies have generated income only through the sale of toddy (not from toddy tapping activity) which is a naturally obtained product – Sale of toddy does not fall in the category of "Collective disposal of labour" - The assessees have not engaged any skill and labour of the members there was not any collective disposal of labour - The toddy tapping is an incidental activity required to be done in order to achieve its main objective of running retail toddy shops – These assessees cannot be considered as Co-operative societies engaged in the collective disposal of labour of its members as contemplated u/s 80P(2)(a)(vi) of the Act – Decided in favour of Revenue.
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