Deposits Wrongly Clubbed with Share Capital – Tribunal Quashes NFAC Order

Keezhuparamba Service Co-operative Bank Ltd. Vs Assessment Unit (ITAT Cochin)

Assessee, a primary agricultural co-operative society registered under the Kerala Co-operative Societies Act, filed revised return of income for AY 2022-23 declaring Nil income after claiming deduction u/s 80P on entire income. Case was selected for scrutiny to verify genuineness of deposits & share capital. AO observed a differential increase of ₹35.05 crore in share capital, treating it as unexplained cash credit u/s 68 & passed order u/s 143(3) r.w.s. 144B on 22.03.2024. CIT(A)/NFAC confirmed

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