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Documents citing Commissioner Of Income-Tax, ... vs Anakapalli Co-Operative Marketing ... on 10 March, 2000

The Nakodar Primary Cooperative Agri. ... vs The Income Tax Officer, Nakodar on 15 March, 2017

The Hon'ble Andhra Pradesh High Court in the case of CIT vs. Anankaplli Co-operative Marketing Society Ltd.(supra), the case law which has been relied on by Assessing Officer has held that if the society is engaged in the business of providing credit facilities to its members and if that society makes any profit and gain out of business attributable to such an activity, then that income earned by the society by way of profit or gain qualifies for exemption under section u/s 8 ITA No.397 & 398(Asr)/2016 Asst. Year: 2010-11 80P(2)(a)(i) of the Act. The miscellaneous income and loan fee are for the facilities of providing credit facilities to the members of the society and has direct nexus with the earnings of the assessee.
Income Tax Appellate Tribunal - Amritsar Cites 8 - Cited by 0 - Full Document

C.I.T vs M/S Sirohi S.B.V.Bank Ltd on 24 September, 2008

Then, we may refer to the judgment of Andhra Pradesh High Court, in Commissioner of Income Tax Nakapalli vs. Anakapalli Co-operative Marketing Society Ltd., reported in 245 ITR 616, wherein it has been held, that twin requirements are to be satisfied being 1. providing credit facility must be one of the activities of the society, and 2. the income attributable to such an activity must be towards profit or gains therefrom should be one of the main source of income, and the income so earned by the society must have a direct or proximate nexus or connection with the business of the society. Then, in that case, it was considered that issuance of certificate, while forwarding the loan applications and recommending the sanction of loan de-hors granting payment, and amount of profit or gains thereby, cannot be said 21 to be activity by a society.
Rajasthan High Court - Jodhpur Cites 14 - Cited by 4 - N P Gupta - Full Document

Shri Avadh Nagarik Sahkari Mandali ... vs The Pr. Cit-1, Rajkot, Rajkot on 31 July, 2024

Hon'ble Andhra Pradesh High Court in the case of CIT v. Anakapalli Co- operative Marketing Society Ltd., [(2000) 245 ITR 616 (AP)], has held that the provisions relating to concessions are ordinarily expected to be rigidly interpreted.The ld PCIT also noted that very basis of functioning of any co- operative society would be the principle of mutuality. However, cooperative banks do not work on the principle of mutuality, hence, the deduction should not be allowed in case of interest earned from cooperative banks by the co- operative society (assessee).
Income Tax Appellate Tribunal - Rajkot Cites 43 - Cited by 0 - Full Document

Rajkot Lodhikasahakari Kharid Vechan ... vs Deputy Commissioner Of Income Tax, ... on 30 September, 2024

Further, the PCIT noted that the exemption and the deduction clauses of the Act, cannot be interpreted liberally. The Hon'ble Apex Court rendered in the case of ITA No.370/RJT/2023 (By Revenue) DCIT vs. Rajkot LodhikaSahakariKharidVechan Sangh Limited and CO No.1/RJT/2024 (By Assessee) Asst.Year-2020-21 -7- Union of India v. Wood Papers Ltd (AIR 1991 SC 2049) and Hon'ble Andhra Pradesh High Court in the case of CIT v. Anakapalli Cooperative Marketing Society Ltd., [(2000) 245 ITR 616 (AP)], has held that the provisions relating to concessions are ordinarily expected to be rigidly interpreted.Theld PCIT also noted that very basis of functioning of any co-operative society would be the principle of mutuality. However, cooperative banks do not work on the principle of mutuality, hence, the deduction should not be allowed in case of interest earned from cooperative banks by the co-operative society (assessee).
Income Tax Appellate Tribunal - Rajkot Cites 41 - Cited by 0 - Full Document

Deputy Commissioner Of Income Tax , ... vs Rajkot Lodhikasahakari Kharid Vechan ... on 30 September, 2024

Further, the PCIT noted that the exemption and the deduction clauses of the Act, cannot be interpreted liberally. The Hon'ble Apex Court rendered in the case of ITA No.370/RJT/2023 (By Revenue) DCIT vs. Rajkot LodhikaSahakariKharidVechan Sangh Limited and CO No.1/RJT/2024 (By Assessee) Asst.Year-2020-21 -7- Union of India v. Wood Papers Ltd (AIR 1991 SC 2049) and Hon'ble Andhra Pradesh High Court in the case of CIT v. Anakapalli Cooperative Marketing Society Ltd., [(2000) 245 ITR 616 (AP)], has held that the provisions relating to concessions are ordinarily expected to be rigidly interpreted.Theld PCIT also noted that very basis of functioning of any co-operative society would be the principle of mutuality. However, cooperative banks do not work on the principle of mutuality, hence, the deduction should not be allowed in case of interest earned from cooperative banks by the co-operative society (assessee).
Income Tax Appellate Tribunal - Rajkot Cites 41 - Cited by 0 - Full Document

The Dcit, Cir-3(2) Gangtok, Gangtok ... vs Sikkim State Cooperative Supply And ... on 18 June, 2025

Provisions relating to concessions are ordinarily expected to be rigidly interpreted: The Hon'ble Apex Court rendered in the case of Union of India v. Wood Papers Ltd (AIR 1991 SC 2049) and the decision of Hon'ble Andhra Pradesh High Court rendered in the case of CIT v. Anakapalli Co-operative Marketing Society Ltd., [(2000) 245 ITR 616 (AP)], wherein it was held that the provisions relating to concessions are ordinarily expected to be rigidly interpreted.
Income Tax Appellate Tribunal - Kolkata Cites 96 - Cited by 0 - Full Document

Deputy Commissioner Of Income Tax, ... vs Sikkim State Cooperative Supply And ... on 18 June, 2025

Provisions relating to concessions are ordinarily expected to be rigidly interpreted: The Hon'ble Apex Court rendered in the case of Union of India v. Wood Papers Ltd (AIR 1991 SC 2049) and the decision of Hon'ble Andhra Pradesh High Court rendered in the case of CIT v. Anakapalli Co-operative Marketing Society Ltd., [(2000) 245 ITR 616 (AP)], wherein it was held that the provisions relating to concessions are ordinarily expected to be rigidly interpreted.
Income Tax Appellate Tribunal - Kolkata Cites 96 - Cited by 0 - Full Document
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