1998 INSC 0913 SUPREME COURT OF INDIA Madras Auto Rickshaw Drivers' Co-Operative Society Vs. Commissioner of Income-Tax (S Bharucha and D Mohapatra JJ.) 10.12.1998 ORDER 1. Heard learned counsel for the appellant and road the judgment under appeal. While we sympathise with what the assessee is doing, we do not think that its activity can be said to provide "credit facilities" to its members. Therefore, the High Court has rightly held that the provisions of Section SOP of the Income-tax Act, 1961, are not applicable. The appeals are dismissed. No order as to costs.