INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
SHRI NARENDRA KUMAR BILLAIYA, AM, SHRI RAJ KUMAR CHAUHAN, JM
ITO 22 3 1 PIRAMAL CHAMBER – Appellant
Versus
ADANI ELECTRICITY EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LIMITED PRABHAT COLONY – Respondent
ORDER
PER RAJ KUMAR CHAUHAN (J.M.):
1. The aforesaid appeal and cross appeal filed by the revenue and appellant/assessee against the order dated 02.07.2024 of Learned Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as the “CIT(A)”], passed under section 250 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] for the A.Y. 2020-21 respectively.
2. Since the facts of appeal filed by the revenue and CO filed by the assessee are exactly same, hence both appeal and CO are taken up together in order to avoid the multiplicity of the decision.
3. The brief facts of the case are that, the assessee is co operative society Registered under Maharashtra Co operative Society Act. The assessee filed a Return of Income on 06.02.2021 declaring total income at Rs. NIL after claiming deduction under Section 80P(2)(d) of the Income tax Act 1961. The AO vide its order dated 12/09/2022 passed an Assessment Order u/s. Subsequently the case was selected for scrutiny under CASS and notices u/s 142(1) alongwith questionnaire were issued and duly served upon the assessee. In response to the notice, assessee filed requisite details through e-fil
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