TMI Blog2013 (5) TMI 1022X X X X Extracts X X X X X X X X Extracts X X X X ..... under Section 80P(2). - ITA Nos. 2671 & 2672/Ahd/2012 & C.O. No. 27 & 28/Ahd/2013 - - - Dated:- 3-5-2013 - Shri D.K.Tyagi, Judicial Member And Shri Anil Chaturvedi, Accountant Member For the Appellant : Shri D. K. Singh, Sr. D.R. For the Respondent : Mrs. Arti N. Shah, A.R. ORDER PER : Anil Chaturvedi, Accountant Member These two appeals are filed by the Revenue and two C.O. are filed by the assessee are against the order of ld. CIT(A)-XX, Ahmedabad, dated 21.09.2012 for the assessment year 2007-08 2008-09 respectively. The Revenue s appeals assessee s C.O. were heard together and are being disposed of by way of this common order for the sake of convenience. 2. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... effective ground raised by Revenue, in both years, is as under: For A.Y. 07-08 1. The Ld. Commissioner of Income-Tax (Appeals)-XX, Ahmadabad has erred in law and on facts in deleting the disallowance of ₹ 12,53,141/- made u/s.80P(2)(a)(i) of the Act. For A.Y. 08-09 1. The Ld. Commissioner of Income-Tax (Appeals)-XX, Ahmadabad has erred in law and on facts in deleting the disallowance of ₹ 10,70,498/- made u/s.80P(2)(a)(i) of the Act. 6. Before us, the ld. Sr. D.R. relied upon the order of the A.O., whereas, on the other hand, ld. A.R. submitted that the assessee is a Co-operative Credit Society which is distinct and separate from Co-operative Bank and it cannot be said to be a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n Section 2(24) and 80P, the assessee was not eligible for deduction u/s.80P was not in accordance with law. He has further held that the assessee is not covered by the Section 80P(4) and also entitled to deduction u/s.80P(2). Nothing has been brought on record by the Revenue to controvert the findings of the CIT(A). In view of the aforesaid facts, we find no reason to interfere with the order of CIT(A) in both years and thus, this ground of Revenue in both years, are dismissed. 8. In the result, Revenue s appeal in both years are dismissed. C.O. Nos. 27 28/Ahd/2013 9. The ground of C.O. reads as under: 1. The Learned Commissioner of Income Tax (Appeals)-XX, Ahmadabad has erred in directed to Asses ..... X X X X Extracts X X X X X X X X Extracts X X X X
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