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2012 (11) TMI 92 - AT - Income TaxAddition on account of income from other sources - Deemed income or Gift u/s 56(2)(vi) - receipt without consideration - interest free unsecured loan – amount received from proprietorship concern of HUF - Held that:- the amount has been clearly reflected in the balance sheet as loan - Assessing Officer himself has recorded in the assessment order that the amount was received from HUF and was recorded in the balance sheet as liability of unsecured loan – addition deleted Capital or revenue expenditure - consultancy charges - consultancy of designing the equipment as per specifications of the export – Held that:- Appellant has been in the business of manufacturing of rectifiers for very long and similar rectifiers had been supplied to different customers earlier than this sale as well - product in question has been designed in house by the assessee and the services provided by M/s Jeet Engineers are only in the nature of facilitating the sales of the product. Even otherwise an amount of Rs. 1,50,000/- is too small to be paid as remuneration for designing of rectifiers. As such there is no evidence to hold that the payment made was for the purposes of designing. The claim of the appellant that the same represents revenue expenditure is correct - addition deleted
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