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2019 Supreme(Online)(ITAT) 317

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
THE AHMEDABAD DIST. CO. OP. BANK LTD. AHMEDABAD – Appellant
Versus
THE DY.COMMISSIONER OF INCOME TAX CIRCLE-7 AHMEDABAD – Respondent


आदेश/ORDER 

PER RAJPAL YADAV, JUDICIAL MEMBER:

Present two appeals are directed at the instance of the assessee against orders of the ld.CIT(A)-10, Ahmedabad dated 10.3.2016 and 25.1.2017 passed for the Asstt.Years 2011-12 and 2012-13. Since common issue is involved in both the appeals, therefore we heard them together and deem it appropriate to dispose of them by this common order.

2. A perusal of the ground would indicate that they are verbatim same except variations of figures in both the assessment years. Sole grievance of the assessee is that the ld.CIT(A) has erred in law as well as on facts in confirming disallowance of the claim for deduction of Rs.3,16,00,000/- and Rs.3,03,14,000/- in respect of investment depreciation reserve in the Asstt.Year 2011-12 and 2012-13.

3. Facts on all vital points are common. Therefore, for the facility of reference, we take up the facts mainly from Asstt.Year 2011-12. Brief facts of the case are that the assessee is a cooperative society engaged in the business of banking. It has filed its return of income for the Asstt.year 2011-12 on 29.9.2011 declaring total income at Rs.10,68,73,920/-. Similarly, in the Asstt.Year 2012-13, it has declared tax

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