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6. The Ld. AR also drew our attention to the decision of the Hon'ble Supreme Court wherein their Lordship upheld the decision of the Hon'ble Bombay High Court in the case of PCIT Vs. M/s. Annasaheb Patel Mathadi Kamgar Sahakari Pathpedi Ltd which in- turn followed the decision of Hon'ble Bombay High Court in the case of Quepem Urban Co-operative Credit Society Ltd. Vs. ACIT (2015) 377 ITR 272 (Bom) & SLP preferred by department dismissed by Hon'ble Supreme Court 235 Taxman 514 (SC). The Hon'ble Supreme A.Y. 2012-13 Rashtriya Chemical and Fertilisers Court in Annasaheb Patel (supra) has affirmed the view of the Hon'ble Bombay High Court by following the ratio laid down in the case of Mavilayi Service Co-operative Bank Limited and Others Vs. CIT, Calicut And Another (2021) 7 SCC 90 which order reversed the full bench decision of the Hon'ble Kerala High Court by holding as under: