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2012 (8) TMI 665 - AT - Income TaxAddition – profit rate - trading (gross) profit for the year at 26% as against the preceding year, where the same stood at 27.77 – Held that:- In the event of the trading results for the immediately preceding year being better than that for the current year, the assessee shall be allowed to present its case before the assessing authority by the ld. CIT(A), and adjudicate in the matter only subsequently Disallowance of the sum paid to directors of the assessee company – Held that:- where payments were made by assessee-company to its directors was supported by a Board resolution which authorised payment being in appreciation of directors' services and encouraging operational results of company, deduction should be allowed to assessee Disallowance in respect of traveling expenses - ad hoc estimates in view of the inability of the assessee to substantiate its claim in this regard in full – Held that:- In the absence of details as the reason, it stood explained by assessee before the ld. CIT(A), that the same is only by way of journal vouchers, to balance the accounts where short payments are received, so that the (personal) accounts of the business associates, being customers (oil companies) to whom cylinders are supplied, have been squared up by writing off the differences, being for minor sums – 10% of the amount is disallowd Deduction u/s. 80IA of the Act – repair or manufacture for the purpose of deduction – Held that:- Repair of cylinders - raw material and finished product is only a gas cylinder, the assessee by its processes removing the deficiency/s, as by way of welding the joints, and effecting improvements, as by way of fixing the bottom and/or the top ring - Rendering a particular thing fit for being used for which it stand already produced or manufactured, i.e., restoring it to good and workable condition, once again, is essentially a repair - assessee's activity only amounts to repair for the purpose of deduction
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