9911796707
TMI Blog2025 (5) TMI 1301X X X X Extracts X X X X X X X X Extracts X X X X ..... ase are that the assessee is a society and is registered under Indian Societies Act, 1860 vide certificate dated 19.12.2009. The society was incorporated with cabinet approval of Govt. of Assam vide notification no.BW-10/2008/73 dated 06.10.2009. The society is registered u/s 12A of the Act vide order for provisional registration is Form 10AC issued by Income Tax Department on 06.04.2022 from the period from A.Y 2022-23 to A.Y 2024-25. As per the Memorandum of Association, the assessee was created for implementation of major infrastructure projects in the State of Assam. For the assessment year 2015-16, the assessee had not filed its return of income u/s 139 of the Act. Subsequently, order u/s 148A(d) of the Act was issued on 31.03.2022 fol ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Rs. 2,00,58,863/- which was reported in the return of income and this amount was also added to the income of the assessee. Accordingly, the Assessing Officer passed the assessment order dated 06.03.2023 by determining total income at Rs. 123,24,74,282/-. 3. Aggrieved by the above order, the assessee preferred an appeal before the ld. CIT(A) which was consequently dismissed by the ld. CIT(A) by confirming the action of the Assessing Officer. Hence, the assessee has come in appeal before us. 4. The ld. AR, before this Tribunal, has raised various grounds of appeal, however, the sum and substance was the challenging of the addition made by the Assessing Officer towards bank interest income of Rs. 121,24,15,419/- and short-term capital gai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n from the consistency which was already followed by the department. 6. We, after hearing the rival contentions and perusing the materials on record, find that the assessee is a government created society with specific objectives for infrastructural development and received grant from the Govt. of Assam and the society was made for carrying out specific purpose. During the assessment year, in question, the income earned i.e. interest from temporary parking of such unutilized funds and short-term capital gains arises from a mere switch between schemes in liquid and mutual funds of the same corpus. In the present case, it is importantly noted that in the assessee's own case for the assessment years 2017-18 and 2020-21, the Assessing Officer ..... X X X X Extracts X X X X X X X X Extracts X X X X
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