TMI Blog1979 (3) TMI 69X X X X Extracts X X X X X X X X Extracts X X X X ..... ies was assessable as business income and as such, exempt under s. 80P(2)(a)(i) of the IT Act, 1961. 2. The facts are that the assessee in Co-operative Society engaged in the business banking. The ITO, after examining the papers filed with the return by the assessee, did not agree with the contention of the assessee that the Government Securities held by the Bank were not investments. According ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecurities are easily realisable and were part of circulating capital to be utilised as and when needed. By very nature of the banking business, the fund has to be utilised for giving advances, making other investments from which income could be earned. The Tribunal, Allahabad in similar circumstances held such Govt. Securities stock in trade in the case of Allahabad Dist. Cooperative Bank Ltd., Al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t., Shri R.N. Shukla and the learned counsel for the assessee, Shri M.M. Sadh. In our view, no interference is called for in the order of the AAC, as in arriving at the above conclusion, he has followed the decision of the Tribunal in the case of Allahabad District Co-operative Bank Ltd. for the asst. yr. 1969-70 (ITA No. 1759 Alld.) of 1972-73. We have also noted that in the subsequent year in th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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