Plea of considering criteria laid down by Circular not acceptable as it cannot have any primacy over Court’s ruling

INCOME TAX : Circulars issued by a Government department cannot have any primacy over decision of jurisdictional High Court, hence plea of assessee of considering criteria laid down by CBDT circular 133/6 of 2007 dated 9-5-2007 over ruling of High Court in Mavilayi Service Co-operative Bank Ltd. v. CIT 2019(2) KHC 287, while ascertaining whether a co-operative society is conducting banking business so as to dis-entitle it for deduction under section 80P(4) could not have been allowed

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