9911796707
TMI Blog2023 (6) TMI 257X X X X Extracts X X X X X X X X Extracts X X X X ..... l Faceless Appeal Centre (NFAC), Delhi dated 10.11.2022, which is arising out of the order under section 143(3) of the Act dated 19.12.2019 framed by Assessing Officer. 2. So far as Grounds No. 1 & 5 are concerned, they relate to the addition made by the ld. Assessing Officer for unexplained money under section 69A of the Act for the alleged cash deposits during demonetisation period by invoking the provisions of section 115BBE of the Act. 3. We, however, from the perusal of the impugned order, notice that the said addition has already been deleted by the ld. CIT(Appeals) in para 5.7.6 of the impugned order holding that there is no merit in the addition made of Rs.17,60,000/- and the same is hereby deleted. Since the addition of Rs.17,60, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee placed the break-up of miscellaneous income stating that all these income are part of regular activities of the Cooperative Society for which it is established for. 6. On the other hand, ld. D.R. supported the order of both the lower authorities. 7. We have heard the rival contentions and perused the relevant record placed before us. The miscellaneous income of Rs.9,92,664/- shown in the Profit & Loss Account has been treated by both the lower authorities as income from other sources. The break-up of the miscellaneous income of Rs.9,92,664/- as provided by the assessee during the course of hearing is reproduced below:- Breakup of Miscellaneous income of Rs. 9,92,664.00 Sl. No. Head of Misce. Income Amount 1 Salary Gran ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... istered bye-laws. We do not find any reason to treat any of the element of miscellaneous income enumerated above as income from other sources. Since the alleged sum of Rs.9,92,664/- is the income earned by the Society for the purpose of its objects, the same is eligible for deduction under section 80P of the Act. We thus reverse the finding of ld. CIT(Appeals) and allow Grounds No. 2, 3 & 4 of the assessee directing the ld. Assessing Officer not to treat Rs.9,92,664/- as income from other sources and the same should be considered as income earned by the Society eligible for deduction under section 80P of the Act. Thus Grounds No. 2, 3 & 4 are allowed. 9. Ground No. 6 is general in nature, which does not call for recording of any reason. 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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