M/S Tumkur Merchants Souharda Credit ... vs Assessee on 19 February, 2014
If it is found that the facts are in line
with the facts in the case of PCIT and Another Vs. Totagars Co-operative Sale
Society (supra), then the issue should be decided against the assessee and if it
is found that the facts of the present case are in line with the facts in the case of
Tumkur Merchants Souharda Credit Cooperative Ltd. Vs. ITO (supra), then the
issue should be decided in favour of the assessee. Needless to say, the ld.
CIT(A) should provide adequate opportunity of being heard to both sides.