12. Undisputedly, the assessee in Schedule - C of the balance sheet has shown
the interest accrued and due but not paid as under:-
Shakkar Vishesh Nidhi Rs.1,18,29,590/-
State Govt. Loan Rs.5,65,34,280/-
UP Cooperative Sugar
Factories Federation Ltd. Rs.1,67,31,128/-
Total Rs.8,50,94,998/-
13. Now, the sole question for determination in this case is, "as to whether the
aforesaid lenders fall in the definition of public financial institution empowering
the AO to invoke the provisions contained u/s 43(d)?" Identical issue has come
up before the coordinate Bench of ITAT, Delhi Bench 'H', New Delhi in ACIT vs.
Baghpat Cooperative Sugar Mills Ltd., ITA No.6157/Del/2012, in assessee's own
case qua the assessment year 2007-08.
