Shree Jamkandorna Taluka Co-Op. Sales ... vs Income Tax Office, Ward 2(1)(2), Rajkot on 20 May, 2025
IN THE INCOME TAX APPELLATE TRIBUNAL ... Hybrid Hearing)
Shree Jamkandorna Taluk a Co-Op. Vs. Income Tax Officer,
Sales & Purchase Unio n Lt d Ward2(1)(2),
C/o . sarda
decision of Supreme Court in the case of Totgars Co-
op. Sale Society Ltd. v. ITO [2020] 188 Taxman 282 (SC), the above
interest income ... thereafter relying on the decision of Supreme Court
in Totgars Co-op. Sale Society Ltd. (supra) held that AO ought to have
taxed the interest
Even Hon'ble Karnataka High Court PCIT v. Tatagars Co-op. Sale Society
[2017] 78 taxmann.com 169 (Karnataka) also held that ... assessee
relied on the following decisions;
PCIT v. Tatagars Co-op. Sale Society [2017] 78 taxmann.com 169
(Karnataka),
Kaliandas Udyog Bhavan Premises Co-operative
laid down by
Supreme Court in the case of Totagars Co. Op. sale Society Ltd. vs. ITO as the
facts of the appellant ... Supreme
Court in the case of Totgars Co-op Sale Society Ltd (supra)
cannot in any way come to the rescue of either
laid down by
Supreme Court in the case of Totagars Co. Op. sale Society Ltd. vs. ITO as the
facts of the appellant ... Supreme
Court in the case of Totgars Co-op Sale Society Ltd (supra)
cannot in any way come to the rescue of either
laid down by
Supreme Court in the case of Totagars Co. Op. sale Society Ltd. vs. ITO as the
facts of the appellant ... Supreme
Court in the case of Totgars Co-op Sale Society Ltd (supra)
cannot in any way come to the rescue of either
laid down by
Supreme Court in the case of Totagars Co. Op. sale Society Ltd. vs. ITO as the
facts of the appellant ... Supreme
Court in the case of Totgars Co-op Sale Society Ltd (supra)
cannot in any way come to the rescue of either
Producers with own mining capability and retail sales; and (c) Export
sales. Also, the OP produces three different grades of Ilmenite ... pricing methodology followed by the
OP or the factors considered by the OP in pricing Ilmenite. As per the OP, the DG has
erred
components Net Margin Profit/Sales
("Manufacturing Method ("OP/Sales")
import") ("TNMM")
Export of 7.82%
manufacturing
goods
("manufacturing
export ... Particulars Scenario 1 Scenario 2
comparable OP/TC Working OP/TC Working
capital capital
adjusted adjusted
OP/TC OP/TC
1. Datamatics Limited Additional
Supreme Court decision in the case of Totgar Co-op. Sales
Society Ltd. and latest Hon'ble Karnataka High Court decision in the case ... PCIT, Hubli v/s. Totgar Co-op. Sales Society 392 ITR 74 (ITA No-
100069/2016). However, the said judgments are not applicable in
Appellant
