Appeal details
Counselvise Citation
[2016] 132 COUNSELVISE.COM (IT) 2158 (ITAT-NAGPUR)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
1 year(s) 5 month(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
05-07-2016
Appeal Filed By
Department
Order Result
Dismissed
Bench Allotted
SMC
Next Hearing Date
09-05-2016
Assessment Year
2010-2011
Appeal Filed On
04-02-2015
Judgement Text
1 ITA NO. 31/NAG/2015 IN THE INCOME TAX APPELLATE TRIBUNAL, NAGPUR BENCH, NAGPUR BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER. (S.M.C.) I.T.A. NO. 31 /NAG/201 5 . ASSESSMENT YEAR : 2010 - 11. THE INCOME - TAX OFFICER , SHRI SANT GAJANAN NAGRI WARD - 4, AMRAVATI. VS. SAHAKARI PAT SANSTHA LTD., WARUD, DIST. AMRAVATI. PAN AAETS5852L. APPELLANT. RESPONDENT. APPELLANT BY : SHRI A. R. NINAWE. RESPONDENT BY : NONE. DATE OF HEARING : 04 - 07 - 2016 DATE OF PRONOUNCEMENT : 5 T H JULY , 2016 O R D E R THIS APPEAL BY THE REVENUE IS DIRECTED AGAINST THE ORDER OF LEARNED CIT(APPEALS) - II, NAGPUR DATED 10 - 11 - 2014 AND PERTAINS TO ASSESSMENT YEAR 2010 - 11. GROUNDS OF APPEAL READ AS UNDER : 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(APPEALS) HAS ERRED IN TREATING THE INTEREST INCOME OF RS.29,45,970/ - AS BUSINESS INCOME SINCE THE SAME IS NOT ATTRIBU TABLE TO THE ASSESSEES BUSINESS OF PROVIDING CREDIT FACILITY TO ITS MEMBERS. 2. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(APPEALS) HAS ERRED IN NOT APPRECIATING THE ASSESSING OFFICERS DECISION THAT INTEREST INCOME OF RS.29,45,970/ - WAS CORRECTLY TAXABLE AS INCOME FROM OTHER SOURCES AS THE SAME WAS EARNED BY THE ASSESSEE ON INVESTMENT MADE IN BANK DEPOSIT AND MUTUAL FUNDS OUT OF ITS SURPLUS FUNDS NOT REQUIRED IMMEDIATELY FOR BUSINESS PURPOSE. 3. ON THE FACTS AND IN THE CIRCUMSTANCES OF TH E CASE, THE LD. CIT(APPEALS) HAS ERRED IN LAW IN NOT FOLLOWING THE DECISION OF THE 2 ITA NO. 31/NAG/2015 HONBLE SUPREME COURT IN THE TOTAGARS CO - OP. SALE SOCIETY LTD. VS. INCOME TAX OFFICER (2010) 322 ITR 283 (SC), WHICH IS SQUARELY APPLICABLE TO THE FACTS IN ASSESSEES CASE. 2. BRIEF FACTS OF THE CASE ARE AS UNDER : RETURN OF INCOME DECLARING INCOME OF RS. NIL WAS FILED ON 28 - 03 - 2011. THE ASSESSEE IS A COOPERATIVE SOCIETY ENGAGED IN THE BUSINESS OF PROVIDING CREDIT FACILITIES TO ITS MEMBERS. THE ASSESSEE HAS CLAIMED DEDUCTI ON U/S 80P AMOUNTING TO RS.14,27,315/ - . DURING THE COURSE OF ASSESSMENT PROCEEDINGS IT WAS NOTED BY THE AO THAT THE ASSESSEE HAD SHOWN INTEREST INCOME AMOUNTING TO RS.29,45,970/ - WHICH WAS RECEIVED FROM THE VARIOUS COOPERATIVE BANKS AND OTHER BANKS. 3. THE AO ASKED THE ASSESSEE TO EXPLAIN AS TO WHY THE INTEREST ACCRUING ON SUCH INVESTMENTS SHOULD NOT BE BROUGHT TO TAX U/S 80P AND DENIED ON THE SAME. IT WAS EXPLAINED BY THE ASSESSEE THAT FUNDS ARE INVESTED BY THE SOCIETY IN VARIOUS INVESTMENTS, WHICH CAN BE READILY AVAILABLE FOR DISBURSING LOANS TO MEMBERS WHEN THEY REQUIRE FINANCIAL ASSISTANCE. THE AO DID NOT AGREE WITH THE SUBMISSIONS OF THE ASSESSEE AND HELD THAT 80P DEDUCTION CAN ONLY BE CLAIMED IN RESPECT OF INTEREST RECEIVED FROM ADVANCES MADE TO MEMBE R S AND THA T SINCE THE SAID INTEREST WAS RECEIVED FROM BANKS, THERE WAS NO QUESTION OF AL LOWING DEDUCTION U/S 80P(2)(A)(I). 4. UPON ASSESSEES APPEAL, LEARNED CIT(APPEALS) DECIDED THE APPEAL IN FAVOUR OF THE ASSESSEE BY REFERRING TO SEVERAL CASE LAWS AND CON CLUDING AS UNDER: 6.4 THUS FROM THE PERUSAL OF THE FACTS OF THE CASE AND VARIOUS JUDICIAL PRONOUNCEMENTS, IT IS EVIDENT THAT THE INTEREST EARNED ON VARIOUS FUND INVESTED BY THE APPELLANT WHICH ARE DEPOSITED IN BANK ACCOUNT ARE DIRECTLY ATTRIBUTABLE TO THE BUSINESS OF BANKING HA S TO BE TAXED THE BUSINESS INCOME OF THE APPELLANT. THERE ARE SEVERAL JUDGEMENT WHICH ARE CLEARLY HELD THAT INTEREST INCOME EARNED BY BANK ON SECURITIES, FDS, INVESTMENTS IN UTI ETC OUT OF MONEY AVAILABLE FROM WORKING CAPITAL 3 ITA NO. 31/NAG/2015 AVAILABLE WITH THE CO - OPERATIV E BANKS ARE ALL INCOME ATTRIBUTABLE TO BUSINESS OF BANKING AND ELIGIBLE FOR GRANT OF DEDUCTION U/S.80P(2)(A)(I). SOME OF THE JUDGEMENTS WHICH SUPPORT THEIR VIEW ARE AS UNDER: - 1. SURAT DISTRICT CO - OP BANK LTD., & ORS VS. ITO (2003) 78 TTJ 1 (AHD, SPL. BENCH) 2. CIT VS., RAMANATHAPURAM DISTRICT CO - OP, CENTRAL BANK LTD.,(2002) 255 ITR 423 (SC) 3. CIT VS. RATNAGIRI DISTRICT CENTRAL CO - OP BANK LTD., (2002) 174 CTR 116 (BOM.) 4. CIT VS. MADURAI DISTRICT CO - OP. BANK LTD., (1991) 239 ITR 700 (MAD.) AND 5. CIT VS. SOLAPUR NAGARI AUDYOGIC SAHAKARI BANK LTD., (2009) 182 TAXMAN, 231 (BOM.) 7. IN CONCLUSION IT MAY BE STATED THAT IN THE APPELLANTS LINE OF BUSINESS, THE APPELLANT HAS TO PAY INTEREST ON THE DEPOSITS IT TAKES AND IT IS NOT POSSIBLE THAT ALL THE DEPOSITS WHICH ARE COLLECT ED MAY BE ADVANCED AT THE SAME POINT OF TIME. IT IS ALSO POSSIBLE THAT SOME DEPOSITS MAY BE WITHDRAWN PRIOR TO ITS MATURITY SO FAR AS FIXED DEPOSIT ACCEPTED ARE CONCERNED AND ANY WITHDRAWALS ARE POSSIBLE FROM SAVING BANK DEPOSITS OR RECURRING DEPOSITS AT A NY POINT OF TIME FOR WHICH SOCIETY CANNOT GO AND RECOVER THE AMOUNT FROM THE BORROWERS AND THEN PAY TO THE DEPOSIT HOLDERS AND HENCE, SOME CIRCULATING CAPITAL OR OPERATIONAL FUNDS BY WAY LIQUID FUNDS ARE ALWAYS REQUIRED TO BE KEPT FOR SMOOTH FUNCTIONING OF THE SOCIETY. EVEN IN CASE OF BANKS, RBI PRESCRIBES SLR AND CLR FOR THIS PURPOSE AND HENCE, FOR MEETING SUCH REQUIREMENTS BANKS HAVE TO KEEP THE FUNDS BY WAY OF LIQUID ASSETS TO MEET SUCH REQUIREMENTS. TO MAINTAIN SUCH OPERATIONAL FUNDS, IS PART AND PARTIA L OF THE LENDING ACTIVITY AND HENCE, IT CANNOT BE SAID THAT THE INCOME BY WAY OF INTEREST FROM OTHER BANKS IS NOT FOR CARY8ING ON THE BUSINESS OF PROVIDING CREDIT FACILITY TO ITS MEMBERS. THE INVESTMENT OF THE FUNDS BY THE BANKS INCLUDING THE NON - STATUARY RESERVES ARE PART OF THE LENDING ACTIVITY AND NO BANK WOULD LIKE ITS RESERVE FUNDS TO REMAIN IDLE AND NOT EARN ANY INTEREST. THIS IS NOT ONLY PRUDENT BUSINESS MANAGEMENT BUT IS ALSO A PART OF THE ACTIVITY OF LENDING, THEREFORE, THE INTEREST EARNED ON SUCH DEPOSITS IS DIRECTLY ATTRIBUTABLE TO THE BUSINESS OF PROVIDING CREDIT FACILITY TO ITS MEMBERS AND THE SAME THEREFORE QUALIFIES FOR THE RELIEF AND DEDUCTION U/S.80P(2)(A)(I) OF I.T. ACT, 1961. 5. AGAINST THE ABOVE ORDER, REVENUE IS IN APPEAL BEFORE THE I TAT. 4 ITA NO. 31/NAG/2015 6. I HAVE HEARD THE LEARNED D.R. NONE APPEARED ON BEHALF OF THE ASSESSEE. HOWEVER, IN MY CONSIDERED OPINION THE ISSUE CAN BE DISPOSED OF BY HEARING THE LEARNED D.R. 7. UPON CAREFUL CONSIDERATION I FIND THAT THE ISSUE IS COVERED IN FAVOUR OF THE ASSES SEE BY VARIOUS DECISIONS INCLUDING THAT FROM THE JURISDICTIONAL HIGH COURT AS REFERRED BY THE LEARNED CIT(APPEALS). FURTHER MORE THE ITAT, NAGPUR BENCH IN ITA NO. 528/NAG/2014 DATED 17 TH JUNE, 2016 IN THE CASE OF ITO VS. SANT AMARDAS URBAN CREDIT CO - OP. SO CIETY LTD. ON SIMILAR GROUNDS OF APPEAL HAS DECIDED THE APPEAL AS UNDER : UPON HEARING THE LEARNED COUNSEL OF THE ASSESSEE AND PERUSING THE RECORDS, WE FIND THAT THE ABOVE ISSUE IS COVERED IN FAVOUR OF THE ASSESSEE BY THE DECISION OF THIS ITAT, REFERRED BY THE LD. CIT(A) IN HIS APPELLATE ORDER. THE DISTINCTION MENTIONED IN THE GROUNDS OF APPEAL IS NOT AT ALL SUSTAINABLE. WE FURTHER FIND THAT THIS TRIBUNAL AGAIN IN THE CASE OF CHATTISGARH URBAN SAHAKARI SANSTHA MARYADIT VS. ITO IN ITA NO.371/NAG/2012 VIDE ORDER DATED 27.05.2015 HAS ADJUDICATED SIMILAR ISSUE AS UNDER: - 11 UPON CAREFUL CONSIDERATION, WE NOTE THAT IDENTICAL ISSUE WAS THE SUBJECT MATTER OF CONSIDERATION BY ITAT, AHMEDABAD BENCH DECISION IN THE CASE OF DHANLAXMI CREDIT COOPERATIVE SOCIETY LTD. (SUPRA), IN WHICH ONE OF US, LEARNED JUDICIAL MEMBER, WAS A PARTY. THE CONCLUDING PORTION OF THE TRIBUNALS DECISION IS AS UNDER: - 4.WITH THIS BRIEF BACKGROUND, WE HAVE HEARD BOTH THE SIDES. IT WAS EXPLAINED THAT THE CO - OPERATIVE SOCIETY IS MAINTAINING OPERATIONS FUNDS AND TO MEET ANY EVENTUALITY TOWARDS RE - PAYMENT OF DEPOSIT, THE CO - OPERATIVE SOCIETY IS MAINTAINING SOME LIQUIDATED FUNDS AS A SHORT TERM DEPOSIT WITH THE BANKS. THIS ISSUE WAS THOROUGHLY DISCUSSED BY THE ITAT BBENCH AHMEDABAD IN THE CASE OF THE INCOME TAX OFFICER VS. M/S.JAFARI MOMIN VIKAS CO - OP. CREDIT SOCIETY LTD. BEARING ITA NO.1491/AHD/2012 (FOR A.Y.2009 - 10) AND CO NO.138/AHD/2012 (BY ASSESSEE) ORDER DATED 31/10/2012. THE RELEVANT PORTION IS REPRODUCED BELOW: - 19. THE ISSUE DEALT WITH BY THE HONBLE SUPREME COURT IN THE CASE OF TOTGARS(SUPRA) IS EXTRACTED, FOR APPRECIATION OF FACTS, AS UNDER: WHAT IS SOUGHT TO BE TAXED UNDER SECTION 56 OF THE ACT IS THE INTEREST INCOME ARISING ON THE SURPLUS INVESTED IN SHORT TERM DEPOSITS AND 5 ITA NO. 31/NAG/2015 SECURITIES WHICH SURPLUS WAS NOT REQUIRED FOR BUSINESS PURPOSES? THE ASSESSEE(S) MARKETS THE PRODUCE OF ITS MEMBERS WHOSE SALE PROCEEDS AT TIMES WERE RETAINED BY IT. IN THIS CASE, WE ARE CONCERNED WITH THE TAX TREATMENT OF SUCH AMOUNT. SINCE THE FUND CREATED BY SUCH BY SUCH RETENTION WAS NOT REQUIRED IMMEDIATELY FOR BUSINESS PURPOSES, IT WAS INVESTED IN SPECIFIED SECURITIES. THE QUESTION, BEFORE US, IS WHETHER INTEREST ON SUCH DEPOSITS/SECURITIES, WHICH STRICTLY SPEAKING ACCRUES TO THE MEMBERS ACCOUNT, COULD BE TAXED AS BUSINESS INCOME UNDER SECTION 28 OF THE ACT? IN OUR VIEW, SUCH INTEREST INCOME WOULD COME IN THE CATEGORY OF I NCOME FROM OTHER SOURCES, HENCE, SUCH INTEREST INCOME WOULD BE TAXABLE UNDER SECTION 56 OF THE ACT, AS RIGHTLY HELD BY THE ASSESSING OFFICER... 19.1. HOWEVER, IN THE PRESENT CASE, ON VERIFICATION OF THE BALANCE SHEET OF THE ASSESSEE AS ON 31.3.2009, IT WAS OBSERVED THAT THE FIXED DEPOSITS MADE WERE TO MAINTAIN LIQUIDITY AND THAT THERE WAS NO SURPLUS FUNDS WITH THE ASSESSEE AS ATTRIBUTED BY THE REVENUE. HOWEVER, IN REGARD TO THE CASE BEFORE THE HONBLE SUPREME COURT (ON PAGE 286) 7....... BEFORE THE ASSESSING OFFICER, IT WAS ARGUED BY THE ASSESSEE(S) THAT IT HAD INVESTED THE FUNDS ON SHORT TERM BASIS AS THE FUNDS WERE NOT REQUIRED IMMEDIATELY FOR BUSINESS PURPOSES AND, CONSEQUENTLY, SUCH ACT OF INVESTMENT CONSTITUTED A BUSINESS ACTIVITY BY A PRUDE NT BUSINESSMAN; THEREFORE, SUCH INTEREST INCOME WAS LIABLE TO BE TAXED UNDER SECTION 28 AND NOT UNDER SECTION 56 OF THE ACT AND, CONSEQUENTLY, THE ASSESSEE(S) WAS ENTITLED TO DEDUCTION UNDER SECTION 80P(2)(A)(I) OF THE ACT. THE ARGUMENT WAS REJECTED BY THE ASSESSING OFFICER AS ALSO BY THE TRIBUNAL AND THE HIGH COURT, HENCE, THESE CIVIL APPEALS HAVE BEEN FILED BY THE ASSESSEE(S). 19.2. FROM THE ABOVE, IT EMERGES THAT (A) THAT ASSESSEE (ISSUE BEFORE THE SUPREME COURT) HAD ADMITTED BEFORE THE AO THAT IT HAD I NVESTED SURPLUS FUNDS, WHICH WERE NOT IMMEDIATELY REQUIRED FOR THE PURPOSE OF ITS BUSINESS, IN SHORT TERM DEPOSITS; (B) THAT THE SURPLUS FUNDS AROSE OUT OF THE AMOUNT RETAINED FROM MARKETING THE AGRICULTURAL PRODUCE OF THE MEMBERS; (C) THAT ASSESSEE CA RRIED ON TWO ACTIVITIES, NAMELY,(I) ACCEPTANCE OF DEPOSIT AND LENDING BY WAY OF DEPOSITS TO THE MEMBERS; AND (II) MARKETING THE AGRICULTURAL PRODUCE; AND (D)THAT THE SURPLUS HAD ARISEN EMPHATICALLY FROM MARKETING OF AGRICULTURAL PRODUCES. 6 ITA NO. 31/NAG/2015 19.3. IN THE PRESENT CASE UNDER CONSIDERATION, THE ENTIRE FUNDS WERE UTILIZED FOR THE PURPOSES OF BUSINESS AND THERE WERE NO SURPLUS FUNDS. 19.4. WHILE COMPARING THE STATE OF AFFAIRS OF THE PRESENT ASSESSEE WITH THAT ASSESSEE (BEFORE THE SUPREME COURT), THE FOLLOWING CLINCHING DISSIMILARITIES EMERGE, NAMELY: (1) IN THE CASE OF THE ASSESSEE, THE ENTIRE FUNDS WERE UTILIZED FOR THE PURPOSES OF BUSINESS AND THAT THERE WERE NO SURPLUS FUNDS; - - IN THE CASE OF TOTGARS, IT HAD SURPLUS FUNDS, AS ADMITTED BEFORE THE AO, OUT OF RETAINED AMOUNTS ON MARKETING OF AGRICULTURAL PRODUCE OF ITS MEMBERS; (2) IN THE CASE OF PRESENT ASSESSEE, IT DID NOT CARRY OUT ANY ACTIVITY EXCEPT IN PROVIDING CREDIT FACILITIES TO ITS MEMBERS AND THAT THE FUNDS WERE OF OPERATIONAL FUNDS. THE ONLY FUND AVAILABLE WITH THE ASSESSEE WAS DEPOSITS FROM ITS MEMBERS AND, THUS, THERE WAS NO SURPLUS FUNDS AS SUCH; - IN THE CASE OF TOTGARS, THE HONBLE SUPREME COURT HAD NOT SPELT OUT ANYTHING WITH REGARD TO OPERATIONA L FUNDS; 19.5. CONSIDERING THE ABOVE FACTS, WE FIND THAT THERE IS FORCE IN THE ARGUMENT OF THE ASSESSEE THAT THE ASSESSEE NOT A CO - OPERATIVE BANK, BUT ITS NATURE OF BUSINESS WAS COUPLED WITH BANKING WITH ITS MEMBERS, AS IT ACCEPTS DEPOSITS FROM AND LEN DS THE SAME TO ITS MEMBERS. TO MEET ANY EVENTUALITY, THE ASSESSEE WAS REQUIRED TO MAINTAIN SOME LIQUID FUNDS. THAT WAS WHY, IT WAS SUBMITTED BY THE ASSESSEE THAT IT HAD INVESTED IN SHORT TERM DEPOSITS. FURTHERMORE, THE ASSESSEE HAD MAINTAINED OVERDRAFT FA CILITY WITH DENA BANK AND THE BALANCE AS AT 31.3.2009 WAS RS.13,69,955/ - [SOURCE: BALANCE SHEET OF THE ASSESSEE AVAILABLE ON RECORD]. 19.6. IN OVERALL CONSIDERATION OF ALL THE ASPECTS, WE ARE OF THE CONSIDERED VIEW THAT THE RATIO LAID DOWN BY THE HONBLE SUPREME COURT IN THE CASE OF TOTGARS CO - OP. SALE SOCIETY LTD. 9SUPRA) CANNOT IN ANY WAY COME TO THE RESCUE OF EITHER THE LD.CIT(A) OR THE REVENUE. IN VIEW OF THE ABOVE FACTS, WE ARE OF THE FIRM VIEW THAT THE LEARNED CIT(A) WAS NOT JUSTIFIED IN COMING TO A CONCLUSION THAT THE SUM OF RS.9,40,639/ - WAS TO BE TAXED U/S.56 OF THE ACT. IT IS ORDERED ACCORDINGLY. 5. RESPECTFULLY FOLLOWING THE ABOVE DECISION OF THE CO - ORDINATE BENCH, WE HEREBY HOLD THAT THE BENEFIT OF DEDUCTION U/S.80P(2)(A)(I) WAS RIGHTLY G RANTED BY LD.CIT(A), HOWEVER, HE HAS WRONGLY HELD THAT THE INTEREST INCOME IS TAXABLE U/S.56 OF THE ACT SO DO NOT FALL UNDER THE CATEGORY OF EXEMPTED INCOME U/S.80P OF THE ACT. THE ADVERSE PORTION OF THE VIEW, 7 ITA NO. 31/NAG/2015 WHICH IS AGAINST THE ASSESSEE, OF LD.CIT(A) IS HEREBY REVERSED FOLLOWING THE DECISION OF THE TRIBUNAL CITED SUPRA, RESULTANTLY GROUND IS ALLOWED. 8. WE FIND THAT THE RATIO OF ABOVE CASE ALSO APPLIES TO THE PRESENT CASE. AS OBSERVED IN THE ABOVE CASE LAW, IN THIS CASE ALSO THE SUBMISSIONS OF THE ASSESSEES COUNSEL IS THAT THE ASSESSEE SOCIETY IS MAINTAINING OPERATIONAL FUNDS AND TO MEET ANY EVENTUALITY TOWARDS REPAYMENT OF DEPOSIT THE COOPERATIVE SOCIETY IS MAINTAINING SOME LIQUIDATED FUNDS AS SHORT TERM DEPOSITS WITH BANKS. HENCE ADHERING TO THE DOCTRIN STAIR DESISES, WE HOLD THAT THE ASSESSEE SHOULD BE GRANTED BENEFIT OF DEDUCTION UNDER SECTION 80P(2)(A)(I). ACCORDINGLY, THE INTEREST ON DEPOSITS WOULD QUALIFY FOR DEDUCTION UNDER THE SAID SECTION. ACCORDINGLY, WE SET ASIDE THE ORDERS OF AUTHORITIE S BELOW AND DECIDE THE ISSUE IN FAVOUR OF THE ASSESSEE. 3. WE FURTHER FIND THAT BATCH OF SIMILAR APPEALS DECIDED BY THE ITAT IN FAVOUR OF THE ASSESSEE HAS ALSO BEEN CONSIDERED BY THE JURISDICTIONAL HIGH COURT. THE HONBLE JURISDICTIONAL HIGH COURT HAS DU LY AFFIRMED THE VIEW OF THIS TRIBUNAL. ACCORDINGLY, IN THE BACKGROUND OF AFORESAID DISCUSSION, WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF LD. CIT(A). 8. RESPECTFULLY FOLLOWING THE AFORESAID DECISION AND IN THE BACKGROUND OF ABOVE D ISCUSSION , I DO NOT FI ND ANY INFIRMITY IN THE ORDER OF LEARNED CIT(APPEALS). 9. IN THE RESULT, THE APPEAL FILED BY THE REVENUE STANDS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON THIS 5 TH DAY OF JULY ,2016. SD/ - ( SHAMIM YAHYA) ACCOUNTANT MEMBER. NAGPUR, DATED: 5 TH JULY , 2016. 8 ITA NO. 31/NAG/2015 COPY FORWARDED TO : 1. SHRI SANT GAJANAN NAGRI SAHAKARI PAT SANSTHA LTD., WARUD, DIST. AMRAVATI. 2. I.T.O., WARD - 4, AMRAVATI. 3. C.I.T. III , NAGPUR. 4. CIT(APPEALS), - II , NAGPUR. 5. D.R., ITAT, NAGPUR. 6. GUARD FILE TRUE COPY BY ORDER ASSISTANT REGIS TRAR, INCOME TAX APPELLATE TRIBUNAL, NAGPUR BENCH, NAGPUR. WAKODE.
