ITO (Intelligence ) issued notice u/s 133 (6) to the assessee for calling for particulars of cash transactions above Rs 1 lakhs with details of account holders in the format prepared by the Authority . The Societies have challenged the validity of the notices. Jurisdiction to issue notice was up held by the CIT (A) and Appellate Tribunal . On appeal by the assessee dismissing the appeal the Court held that , ITO (Intelligence ) is an authority to issue notice under section 133(6) to the assessee Co -Operative banks prior to CBDT Notification No 77 of 2014 dt 10 -12 -2014 (AY. 2010-11 to 2012-13 )
Enanalloor Service Co-op. Bank Ltd. v. ITO (2020) 317 CTR 191 (Ker) (HC)
S. 133 : Power to call for information – Authorities – ITO (Intelligence ) is an authority to issue notice under section 133(6) to the assessee Co -Operative banks prior to CBDT Notification No 77 of 2014 dt 10 -12 -2014 [ S. 90, 90A, 120, 124, 133(6), 272A(2)(c)]