2008 Supreme(Raj) 2505
N.P.GUPTA, KISHAN SWAROOP CHAUDHARI
C. I. T. – Appellant
Versus
M/s Sirohi S. B. V. Bank Ltd. – Respondent
Advocates:
For the Appellant:Mr. K.K. Bissa, Advocate.
For the Respondent:Mr. J.L. Purohit, Advocate.
JUDGMENT
1. 1. These three appeals, arise in identical circumstances, and involved, common question-of law; though arise form different orders of the ITAT. The appeals No. 56/07 and 105/06, arise out of the common judgment of the Tribunal, dated 25.1.2006, for the assessment years 1998-1999, and 2000-2001, whereas appeal No.31/2007, arise out of the judgment of the Tribunal, dated 09.6.2006 relating to the assessment year 2003-2204. All the three appeals relate to same assessee. These appeals were admitted on different dates, framing substantial question of law, though in different language, however the substantial question of law, involved in all the three appeals is as under :
"Whether in the facts and circumstances of the case, the amount of interest earned by the respondent Bank on various loans extended to its employees from deposit of P.F. and Housing loan is eligible to the exempted under Section 80P(2)(a)(i) of the Act, 1961."
2. The necessary facts are that the assessee is a co-operative society, and carries on banking activities, including providing credit facilities to its members. In the relevant assessment years, certain additions were made by the assessing officer on ac
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