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2021 (12) TMI 820 - AT - Income TaxDisallowance of rate difference and discount - HELD THAT:- Assessee was consistently making the claim of discount and rate difference on the sale of seeds to its customers. Such claims though disallowed at the end of the AO, but the same were allowed by the CIT(A) and thereafter in appeal by the Revenue, order of the ld. CIT(A) was upheld by the Tribunal. Though the fate of earlier claim of the assessee was very much on record, the ld. AO has ritually rejected claim of the assessee year after year without making any logical end. It has time and again stated by the assessee, recorded by the ld. CIT(A) and taken note by the Tribunal that the assessee is giving discount/rate deduction to customers as per its business policy, which are supported by circulars issued from time to time. The entire payment has been reflected in the ledger account of various dealers and supported by the evidences. The ratio of discount to the turnover is very consistent from year 2008-09, which has been demonstrated before the lower authorities, so was the ratio of gross profit. There was nothing on record before the ld. AO that claim of the assessee was not genuine or non-existent, he has mechanically followed his predecessor's order to reject, otherwise a justifiable claim of the assessee. Therefore, as observed earlier, since identical issue has been considered in favour of the assessee by the co-ordinate benches of the Tribunal from the Asstt. Year 2010-11 upto the Asstt. Year 2012-13, following the same, we reject this ground of appeal, and dismiss appeal of the Revenue.
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