TMI Blog2017 (9) TMI 1998X X X X Extracts X X X X X X X X Extracts X X X X ..... ty's own toddy shops - assessee purchase of toddy from its members and non- members on payment of the agreed remuneration and its sale through the toddy shops established by the society itself - income of the society has nothing to do with the collective disposal of the labour of its members but is entirely from out of the price realised by it for the sale of toddy through the society's ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nvolved relates to the claim of deduction by the assessee under section 80P(2)(a)(vi) of the Act. 2. We have heard the rival submissions, carefully considered the same along with the orders of the tax authorities below. We noted as per the copy of the decision filed by Learned D. R. that the impugned issue whether the assessee is entitled for deduction under section 80P(2)(a)(vi) of the Act has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... antity of toddy delivered. On similar terms, toddy is collected from the non-members also. The bye-laws of the society shows that the main object of the society is establishment and management of the toddy shops. The activity of the society is, therefore, purchase of toddy from its members and non- members on payment of the agreed remuneration and its sale through the toddy shops established by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on is generated out of the collective disposal of the labour of the appellant-societies. 15. The society does not dispute the correctness of the factual finding that toddy is collected from non-members also. Though this was attempted to be explained by the learned counsel by pointing out that there are persons who supplied toddy till they became eligible for admission to the Toddy Workers Welfa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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