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2019 Supreme(Online)(ITAT) 2336

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI RAM PISTON AND RINGS EMPLOYEES SALARY EARNERS CO-OP. CREDIT AND THRIFT SOCIETY LTD. GHAZIABAD – Appellant
Versus
ITO WARD- 2(3) GHAZIABAD – Respondent


ORDER

These four appeals have been filed by assessee against separate orders of ld. Commissioner of Income Tax (Appeals) all dated 31.10.2018.

2. The assessee has taken similar grounds of appeal and these were heard together. Therefore, for the sake of convenience a common and consolidated order is being passed.

3. The grounds of appeal taken by assessee in ITA No.123/Del/2019 are reproduced below:

“1. Because the Id. C1T(A) has erred on law and facts in confirming the assessment order making an addition of Rs 29,82,822/-.

2. Because the CIT(A) has grossly erred in upholding disallowance of the deduction u/s 80P of the Act as she failed to follow the decision of Hon’ble Delhi ITAT in the appellant’s own case in ITA no. 1794/Del/ 2015 as the issue is squarely covered by the aforesaid judgment which is binding on her.

3. Because the CIT(A) has erred on law and facts and failed to appreciate that appellant is not a Cooperative bank in terms of Sec. 80P(4) of the Act, and thus the appellant is duly entitled to deduction in terms of sec 80P(2)(a)(i) of the Act.

4. Because the C1T(A) has further erred in recording wrong facts, and wrongly invoking the principle of mutuality while the present ca

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