COMMISSIONER OF INCOME TAX Vs. KRIBHCO

JUDGEMENT

(1.) Revenue by this appeal, which pertains to the Assessment Year 2006-07, impugns findings recorded by the Income Tax Appellate Tribunal (tribunal, for short) in their order dated 8 th April, 2010 on the question of disallowance under Section 14A of the Income Tax Act, 1961 (Act, for short).

(2.) The respondent-assessee is a cooperative society and comes within the administrative control of the Department of Fertilizers, Ministry of Agriculture and Co-operation, Government of India. The principal business of the assessee is manufacture of urea and ammonia. It is also engaged in marketing of fertilizers and purchase and processing of seeds. It earns interest income from banks, financial institutions, cooperatives etc. and earns service charges from Hazira Ammonia Extension Project etc.

(3.) For the assessment year in question, in the return filed on 30 th October, 2006, the respondent-assessee had declared total income of Rs.2,82,50,91,480/-.