|
Advanced Search Options
Case Laws
Showing 101 to 120 of 459 Records
-
2001 (5) TMI 849
Issues:
1. Denial of SSI exemption on products due to brand name usage.
2. Classification of goods as animal feed supplements.
3. Imposition of penalties under Rule 173Q(1) and Rule 173Q(2).
Analysis:
1. The judgment involved two appeals and a cross objection regarding the denial of SSI exemption on certain products due to the usage of the brand name 'VETCARE' and the imposition of penalties under Rule 173Q(1). The Collector had held that the products Halquinol and Sanitech were not eligible for the SSI Notification benefit due to the use of the brand name belonging to another company not entitled to SSI exemption. However, the Tribunal found discrepancies in the evidence presented, especially regarding the non-disclosure of labels crucial for determining the nature of the goods. The Tribunal concluded that the non-disclosure of labels by the appellant led to an incorrect finding by the Collector and ordered a remand for re-determination.
2. The second issue pertained to the classification of goods as animal feed supplements under heading 2302.00 of the Central Excise Tariff Act, 1985. The Collector had proposed to classify certain products elsewhere, but the Tribunal disagreed and found that the goods 3-CARE and COLIDOX were rightly classifiable as animal feed supplements. The Tribunal highlighted that since these goods were classified under 2302 and eligible for exemption, there was no need to determine whether they were branded or not. The Tribunal set aside the order and allowed the appeals for a remand for de novo adjudication.
3. Regarding the imposition of penalties under Rule 173Q(1) and Rule 173Q(2), the Tribunal found that while a penalty of Rs. 500 was imposed for contravening duty payment rules on specific branded goods, there was no case for the imposition of penalty and confiscation under Rule 173Q(2). The Tribunal's decision to remand the case for re-determination encompassed all aspects, including the penalties imposed, leaving the classification and other points open for further adjudication before the Adjudicating Authority. Ultimately, the Tribunal set aside the order and allowed the appeals by remanding the case for de novo adjudication, emphasizing the need for a thorough re-examination of the issues involved.
-
2001 (5) TMI 848
The Appellate Tribunal CEGAT, New Delhi dismissed the Reference Application as not maintainable because it did not arise out of an order passed in terms of Section 35C(1) of the Central Excise Act, even though it was filed within the statutory period of limitation.
-
2001 (5) TMI 847
The Appellate Tribunal CEGAT, Kolkata upheld the Commissioner (Appeals) order extending the benefit of Notfn. No. 32/99 to the respondents, stating that late filing of statements under condition 2(a) of the notification does not deny substantive benefit. The Tribunal found that the late filing of a separate statement does not result in denial of the substantive benefit available to the respondents. The Tribunal rejected the Revenue's appeals, citing a previous order on the same notification.
-
2001 (5) TMI 844
The judgment is about an application filed under Section 35C(2) of the Central Excise Act, 1944 for a review of a Tribunal order reducing personal penalties to 25%. The application was rejected as there was no provision for review by the Tribunal itself. The plea regarding the jurisdiction of the Asstt. Commissioner was considered and rejected, and it was found that penalties were imposed under Rule 173Q, not Section 11AB. The application was rejected as it did not present new grounds and was not a valid rectification of mistake application.
-
2001 (5) TMI 843
The Appellate Tribunal CEGAT, New Delhi upheld the imposition of duty and penalty on the appellant for not paying duty on goods used in Research and Development Section. The appellant was directed to make a pre-deposit of duty amounting to Rs. 4 lakhs within six weeks. The penalty amount was waived temporarily. Compliance was to be reported by June 27, 2001.
-
2001 (5) TMI 840
The Appellate Tribunal CEGAT, Kolkata allowed the appeals and set aside the order of the Commissioner of Customs (Appeals) due to dismissal on the ground of defective signatures without giving an opportunity to rectify the defect. The appeals are remanded for disposal on merits after giving the appellants a chance to remove any defects. Stay petitions are also disposed of.
-
2001 (5) TMI 816
Issues:
- Appeal against cancellation of penalty under section 271(1)(c) of Income-tax Act
Analysis:
1. The case involved an appeal by the Revenue against the cancellation of a penalty of Rs. 71,830 levied under section 271(1)(c) of the Income-tax Act by the CIT(A). The penalty was imposed due to a shortfall in stock found during a survey at the assessee's premises, leading to the rejection of books of account and estimation of sales by the Assessing Officer.
2. The survey revealed a significant discrepancy in stock, with the assessee providing explanations for the difference, including sending goods for dying and consignment sales. However, the Assessing Officer rejected these explanations, estimating sales at a higher figure and applying a flat rate of profit. The CIT(A) considered the explanations and deleted the penalty, emphasizing that the rejection of books and estimation of sales alone cannot warrant a penalty for concealment of income.
3. The CIT(A) noted that all sales, including consignment sales, were reflected in the trading account, and any discrepancies did not amount to concealment as the profits were duly accounted for. The delay in providing explanations was justified by the appellant, and the CIT(A) concluded that no penalty could be levied under section 271(1)(c) based on the facts presented.
4. Upon review, the Tribunal upheld the CIT(A)'s decision to cancel the penalty, highlighting that the addition to income was made by rejecting the books of account and applying a flat rate of profit on estimated sales. The Tribunal emphasized that discrepancies in stock or rejected explanations do not automatically imply concealment of income or furnishing inaccurate particulars.
5. The Tribunal dismissed the appeal, affirming the cancellation of the penalty. Additionally, it clarified that the cases cited by the Revenue were not applicable due to factual distinctions, further supporting the decision to uphold the CIT(A)'s order.
In conclusion, the Tribunal affirmed the cancellation of the penalty under section 271(1)(c) by the CIT(A), emphasizing that discrepancies in stock, rejected explanations, and estimation of sales do not necessarily indicate concealment of income, especially when all transactions were reflected in the accounts and profits were duly reported.
-
2001 (5) TMI 815
Issues:
Appeal against order dated 13-7-1996 for assessment year 1995-96; Department's grounds under sections 201(1) and 201(1A) of the Act; Cross objection regarding merit of appeal and verification of Form No. 15H; Levying interest and tax for non-deduction of tax at source on interest payments; Validity of Form No. 15H filing; Jurisdiction of ITO; Humanitarian grounds consideration.
Analysis:
The appeal before the Appellate Tribunal ITAT Cuttack involved a dispute arising from an order dated 13-7-1996 for the assessment year 1995-96. The Department's appeal challenged the setting aside of orders under sections 201(1) and 201(1A) of the Act by the DCIT(A), Cuttack, while the assessee filed a Cross objection against the appeal. The Department contended that tax was deductible on interest payments of Rs. 1,63,701 made by a firm, and the ITO treated the assessee as a defaulter for non-deduction of tax at source. The Department argued that Form No. 15H was either not filed or invalid, making the non-deduction a violation of section 194A, leading to the application of sections 201(1), 201(1A), and 201(2) of the Income-tax Act. The Department justified the demand of TDS and interest under section 201. However, the assessee's representative argued that the ITO lacked jurisdiction to levy tax and interest under section 201/201(1A) for non-filing or delayed filing of Form 15H. The representative highlighted the health condition of the managing partner suffering from brain cancer.
The Tribunal considered the legal arguments presented by both parties and concluded that the ITO should have shown leniency on humanitarian grounds, especially considering the managing partner's health condition. The Tribunal found that the ITO had exceeded his authority and jurisdiction by passing orders under section 201/201(1A), deeming it as an act of over-enthusiasm. Consequently, the departmental appeal was dismissed, and the cross-objection filed by the assessee was upheld. The Tribunal's decision was based on the lack of authority of the ITO to pass such orders and the exceptional circumstances surrounding the case, emphasizing the importance of considering humanitarian aspects in tax matters.
-
2001 (5) TMI 813
Issues:
1. Condonation of delay in filing Departmental appeal.
2. Addition of interest payment in the matter of claim of interest payment.
3. Allowance of rebate under section 88 for amount deposited in P.P.F. A/c.
Condonation of Delay in Filing Departmental Appeal:
The Department's appeal was found to be time-barred by 25 days. The Department filed a condonation petition citing unavoidable circumstances for the delay. Initially, the assessee's counsel contested the condonation, arguing that specific reasons were not provided. However, later in the proceedings, the counsel withdrew the objection, acknowledging typical causes of delay in Departmental appeals. Consequently, the delay was condoned, and the appeal was admitted.
Addition of Interest Payment in Claim of Interest Payment:
The assessee earned income from capital gains, dividends, and interest during the relevant year. The dispute centered on the addition of Rs. 10,506 to the claim of interest payment, which had been deleted in the first appeal. The Assessing Officer disallowed the claim, stating that the overdrafts from the bank were diverted for purposes other than those intended, such as providing loans to other entities. However, it was argued that if the loans were indeed diverted to activities generating income for the assessee, the interest payment should be allowed against the interest income taxed under "other sources" and section 57(iii). The Tribunal confirmed the allowance of the interest payment, disagreeing with the Department's grounds and noting the specific circumstances of the case.
Allowance of Rebate under Section 88 for Amount Deposited in P.P.F. A/c.:
The contention revolved around the eligibility for a rebate under section 88 for the amount deposited in the P.P.F. A/c. The assessee argued that the contribution to the P.P.F. came from the current year's income deposited in the bank A/c., not as a loan. Citing judgments from the Orissa High Court and a previous ITAT order, it was maintained that the contribution should be considered as part of the income chargeable to tax for the year. The Tribunal agreed with the assessee, concluding that the P.P.F. contribution was from the assessee's taxable income and upheld the relief under section 88. The Tribunal also referenced relevant precedents to support its decision.
In conclusion, the Departmental appeal was dismissed, with the Tribunal ruling in favor of the assessee on both the issues of interest payment and rebate under section 88.
-
2001 (5) TMI 810
Issues:
- Interpretation of deduction under section 48(2) of the Income-tax Act for capital gains.
- Determination of whether the asset qualifies as a long-term capital asset.
Interpretation of deduction under section 48(2) of the Income-tax Act for capital gains:
The case involved a dispute regarding the deduction under section 48(2) of the Income-tax Act for capital gains earned by the assessee on the sale of an industrial plot. The Assessing Officer initially denied the deduction, arguing that the time interval between the plot's allotment and sale was less than one year, making the capital gain a short-term gain. The assessee contended that the entire cost of the plot, including an enhanced amount paid in 1984, had been settled before physical possession was granted in 1988, thereby qualifying the asset as a long-term capital gain. The assessee cited relevant legal precedents and a Board's circular to support their claim.
Determination of whether the asset qualifies as a long-term capital asset:
The dispute also centered around whether the asset in question could be classified as a long-term capital asset, impacting the eligibility for the deduction under section 48(2). The assessee argued that the date of payment of the enhanced amount in 1984 should be considered as the point when ownership of the plot was acquired, thus categorizing it as a long-term asset. The ld. CIT(A) considered the Tribunal's decision in a similar case and a Board's circular clarifying the treatment of assets upon allotment. The ld. CIT(A) ruled in favor of the assessee, deeming the profit from the plot's sale as a long-term capital gain.
In the final judgment, the judge upheld the decision of the ld. CIT(A), emphasizing alignment with the Board's Circular No. 471 and the principles established by the Tribunal in previous cases. The judge found no fault with the ld. CIT(A)'s ruling, which was supported by legal precedents and authoritative guidelines. Consequently, the appeal filed by the revenue was dismissed, and the CO filed by the assessee, which supported the ld. CIT(A)'s decision, was also deemed infructuous and dismissed.
-
2001 (5) TMI 809
Issues Involved:
1. Computation of notional interest on deposits with M/s. Bijli Cotton Mills, Hathras (BCM).
2. Addition of Rs. 2,885 as unexplained expenditure for the assessment year 1979-80.
3. Addition of short interest/rent received for the assessment years 1983-84, 1984-85, and 1985-86.
4. Levy of interest under section 139(8)/215/217 of the Act for the assessment years 1985-86 and 1986-87.
Issue-wise Detailed Analysis:
1. Computation of Notional Interest:
The primary issue in all the years pertains to the computation of notional interest on deposits made with M/s. Bijli Cotton Mills (BCM). The Assessing Officer (AO) noted that the assessee had not declared any interest income from BCM for the assessment years 1979-80 to 1986-87, despite having done so up to the assessment year 1978-79. The assessee explained that BCM was taken over by the Government and later nationalized, and the compensation awarded was insufficient to cover the dues of higher-priority creditors, leaving nothing for the assessee. The AO, however, applied a 15% interest rate, later modified to 12% by the Commissioner of Income Tax (Appeals) [CIT(A)], and included the notional interest in the taxable income. The Tribunal held that since the principal amount ceased to exist due to nationalization, there was no accrual of interest. Thus, the addition of notional interest was deleted for all the years under consideration.
2. Addition of Rs. 2,885 as Unexplained Expenditure:
For the assessment year 1979-80, the AO added Rs. 2,885 as unexplained expenditure under section 69C of the Act, which was sustained by the CIT(A). The Tribunal noted that while the addition under section 69C was justified, the assessee was entitled to a deduction for the actual expenditure incurred. Thus, the AO was directed to allow the deduction, and the ground of appeal was decided with these observations.
3. Addition of Short Interest/Rent Received:
In the assessment years 1983-84, 1984-85, and 1985-86, the AO added amounts for short interest/rent received from M/s. S.B. Industries, which was upheld by the CIT(A). The assessee argued that rental and interest income were accounted for on an actual receipt basis, which could vary each year. The Tribunal agreed that variations in actual receipts could not justify the additions and thus deleted the additions sustained by the CIT(A) for these years.
4. Levy of Interest under Section 139(8)/215/217:
The assessee challenged the levy of interest under section 139(8)/215/217 of the Act for the assessment years 1985-86 and 1986-87. However, as these grounds were not pressed during the hearing, they were dismissed.
Conclusion:
The Tribunal partly allowed the appeals for the assessment years 1979-80, 1985-86, and 1986-87, and fully allowed the appeals for the assessment years 1980-81, 1981-82, 1982-83, 1983-84, and 1984-85.
-
2001 (5) TMI 794
Issues:
1. Confiscation of goods and currency, levy of penalty.
2. Retraction of confessional statement.
3. Seizure of foreign exchange and Indian currency.
4. Allegations of dealing in goods of foreign origin.
5. Arguments regarding the seized goods and currency.
6. Corroboration of statements by involved parties.
7. Confiscation under Sections 111(d) and 121 of the Customs Act.
8. Reduction of penalty imposed.
Confiscation of Goods and Currency, Levy of Penalty:
The case involved the interception and search of individuals resulting in the seizure of foreign exchange, Indian currency, and goods of foreign origin. The Deputy Commissioner of Customs issued a show cause notice alleging liability to confiscate the goods and currency, imposing a penalty on one of the individuals. The Tribunal upheld the confiscation of certain goods but set aside the confiscation of others, considering the quantities and trade relevance. The confiscation of foreign exchange was upheld under specific sections of the Customs Act, while the penalty imposed was reduced from Rs. 1 lakh to Rs. 20,000 due to financial difficulties faced by the individual.
Retraction of Confessional Statement:
One individual had initially made a confessional statement which was later retracted, citing coercion and health concerns. The Tribunal considered the retraction but found substantial corroboration of the statement by another involved party. Despite the retraction, the confessional statement was deemed of evidential value, leading to the confiscation of goods and currency based on the corroborative evidence.
Seizure of Foreign Exchange and Indian Currency:
The seizure of foreign exchange and Indian currency from the individuals led to allegations of dealing in goods of foreign origin. Various statements and claims were made regarding the ownership and purpose of the seized currency. The Tribunal examined the claims and found them illogical and unsupported, upholding the confiscation of the currency under relevant sections of the Customs Act.
Allegations of Dealing in Goods of Foreign Origin:
The involved individuals were alleged to be dealing in goods of foreign origin based on statements and corroborative evidence. Despite attempts to refute the allegations, the Tribunal found sufficient evidence to support the claims of dealing in such goods, contributing to the decision on confiscation and penalties.
Arguments Regarding Seized Goods and Currency:
Legal arguments were presented regarding the seized goods and currency, including claims of ownership, purpose, and trade relevance. The Tribunal carefully considered these arguments but ultimately upheld the confiscation of certain items based on the evidence and provisions of the Customs Act.
Corroboration of Statements by Involved Parties:
The Tribunal noted the corroboration of statements made by the involved parties, strengthening the evidential value of the confessional statement and supporting the decisions on confiscation and penalties based on the corroborative evidence provided.
Confiscation under Sections 111(d) and 121 of the Customs Act:
Confiscation of goods and currency was upheld under specific sections of the Customs Act, considering the circumstances, claims, and evidence presented during the proceedings. The Tribunal analyzed the legality and logic of the claims made, leading to the decisions on confiscation under the relevant sections.
Reduction of Penalty Imposed:
While upholding the propriety of the penalty imposed, the Tribunal deemed it appropriate to reduce the quantum of the penalty due to the financial difficulties faced by the individual involved. The reduction from Rs. 1 lakh to Rs. 20,000 was considered reasonable and justifiable based on the circumstances presented during the proceedings.
Conclusion:
In conclusion, the Tribunal allowed the appeal in part, upholding certain confiscations and penalties while setting aside others based on the evidence, statements, and legal arguments presented during the case. The reduction of the penalty imposed reflected a balance between legal obligations and the individual's financial situation, ensuring a fair outcome in light of the complex circumstances surrounding the case.
-
2001 (5) TMI 792
The Rectification of Mistake Application was filed by M/s. Vax Institute Laboratory Ltd. regarding a Final Order. The Third Member upheld the duty demand and rejected the appeal. The applicant claimed certain arguments were not reflected in the Order, but the Tribunal found no error and dismissed the application.
-
2001 (5) TMI 791
Issues:
Rectification of mistake (ROM) application filed by M/s. U.P. State Electricity Board for consideration of earlier decisions and notification No. 51/78, appeal filed in the Supreme Court, non-following of earlier Tribunal decisions, recall of order, review of the order already passed, disagreement with the Tribunal's decision, duty amount confirmation, penalty set aside, consideration of case law, adjustment for time-barred period, overlapping demand, dismissal of ROM application.
Rectification of Mistake Application:
M/s. U.P. State Electricity Board filed a Rectification of Mistake (ROM) application seeking consideration of earlier decisions and notification No. 51/78, requesting the benefit under the same and setting aside the order of the Commissioner of Central Excise, Kanpur-II. The Tribunal noted the grounds presented by the appellant for recall of the order, but the Tribunal emphasized that the order, once passed based on arguments from both sides, cannot be recalled. Reference was made to a Larger Bench decision of the Tribunal to support this stance.
Appeal in Supreme Court:
The appellant had filed an appeal in the Supreme Court against the Tribunal's order, which was subsequently dismissed as withdrawn by the Supreme Court. The appellant's counsel referred to earlier Tribunal decisions not followed in the present order, highlighting grounds A and C where multiple decisions were cited. Despite the appellant's contentions, the Tribunal found no merit in the ROM application, emphasizing that the review of the already passed order was not warranted.
Confirmation of Duty Amount:
The Tribunal confirmed the duty amount but set aside the penalty of Rs. 20,000. The Tribunal considered the arguments presented by both sides during the proceedings and referenced various decisions cited by the appellant. The Tribunal aligned with the adjudicating authority's view, as evidenced in the order, and found no justification for the recall of the order based on the arguments presented by the appellant.
Consideration of Case Law and Dismissal of ROM Application:
The Tribunal reviewed the case law cited by the appellant in light of the facts of the case. The Tribunal agreed with the analysis of the facts in the earlier order and upheld the duty amount confirmed by the Commissioner of Central Excise, Kanpur-II. Despite the appellant's plea regarding the case being considered afresh, the Tribunal found no merit in this argument and dismissed the ROM application, affirming the Commissioner's decision.
In conclusion, the Tribunal dismissed the Rectification of Mistake application, maintaining the confirmation of the duty amount and the setting aside of the penalty, while emphasizing the lack of merit in the appellant's requests for a review or recall of the order based on the arguments and case law presented.
-
2001 (5) TMI 790
The Appellate Tribunal CEGAT, Bangalore considered whether turn-over tax paid/payable is deductible in determining the assessable value under Section 4 of the Central Excise Act. The Tribunal followed the Supreme Court decision in the case of Asstt. Collector of Central Excise v. Bata India Ltd. and allowed the appeal, providing consequential relief.
-
2001 (5) TMI 788
Issues:
1. Waiver of deposit of duty and penalty under Section 11AC of the Act.
2. Eligibility for exemption under Notification 108/95.
3. Invocation of extended period under Section 11A of the Act.
4. Knowledge of loan closure by the manufacturer.
5. Limitation period for duty demand and penalty imposition.
Analysis:
1. The manufacturer was awarded a contract by MSEB for a project funded by the World Bank, exempting goods supplied to such projects under Notification 108/95. The manufacturer cleared consignments without duty payment based on this notification between June 1998 and December 1999.
2. The World Bank suspended the loan to MSEB by October 1996, leading to subsequent developments between the Indian and Maharashtra governments. The department issued a notice in 2000 demanding duty on clearances, stating the project was no longer World Bank-funded. The Commissioner confirmed the duty demand and imposed penalties.
3. The manufacturer argued against the extended limitation period, claiming ignorance of the loan closure until a visit in December 1999. The Tribunal found the Commissioner's basis for invoking the extended period unclear and accepted a deposit offer of Rs. 25 lakhs to waive the remaining duty and penalties.
4. The Tribunal vacated an order detaining goods for recovery of the demanded amount. The decision highlighted the lack of clear evidence indicating the manufacturer's knowledge of the loan's closure, leading to a waiver of the remaining duty and penalties upon the deposit made.
5. The judgment focused on the manufacturer's awareness of the loan status, the invocation of the extended limitation period, and the subsequent waiver of duty and penalties upon a deposit offer. The Tribunal's decision emphasized the need for clear evidence to establish knowledge for invoking extended periods under the Act and highlighted the importance of timely compliance and deposit in such cases.
-
2001 (5) TMI 784
The Appellate Tribunal CEGAT, Kolkata ruled in favor of the appellants regarding the availability of benefit of Notification No. 287/86-C.E. for their 'Speciality Oils' products. The decision was based on a previous ruling where the issue was rejected in favor of the Revenue. The impugned order was set aside, and the appeal was allowed with consequential reliefs to the appellants.
-
2001 (5) TMI 783
The Appellate Tribunal CEGAT, Mumbai upheld the reversal of credit on capital goods but reduced the penalty to Rs. 5,000 from Rs. 2,47,154. The tribunal cited a Supreme Court order stating that the maximum penalty limit is not mandatory. The appeal was allowed in favor of the appellant.
-
2001 (5) TMI 782
Issues:
Appeal against duty demand and penalty imposition based on irregular Modvat credit availed under Rule 57-I(i) and (ii) of the C.E. Rules, read with Section 11A(1) of the C.E. Act, 1944.
Detailed Analysis:
1. Duty Demand and Penalty Imposition:
The appeal stemmed from the Order-in-Original confirming duty demand of Rs. 6,65,736 and imposing a penalty of the same amount under Rule 173Q for irregularly availing Modvat credit. The appellants raised legal pleas justifying the Modvat credit availed, particularly regarding the Central Value Duty (CVD) paid on shortages. Despite admissions during investigation, the Commissioner upheld the duty demand, citing that no credit could be availed on duty paid for shortages. The appellants argued that as CVD was paid based on the invoice quantity regardless of shortages, Modvat credit should be allowed. The Commissioner's order lacked detailed findings on the legal submissions, leading to the conclusion that it was not a speaking order.
2. Legal Submissions and Findings:
The appellants contended that the Commissioner failed to address all legal pleas raised, resulting in an incomplete order. The Commissioner's decision was based on admissions without providing explicit findings on the legal arguments presented. The lack of detailed reasoning on the legal contentions rendered the order insufficient. The appellants emphasized the necessity for a comprehensive assessment of all legal points raised to ensure a fair and just decision.
3. Remand and Reconsideration:
After considering submissions from both sides, the Tribunal acknowledged the validity of the Commissioner's reliance on appellants' admissions but highlighted the Commissioner's failure to address the legal submissions adequately. Consequently, the Tribunal set aside the impugned order and remanded the matter to the Commissioner for a fresh consideration. The Commissioner was instructed to provide a speaking order by thoroughly examining all points raised by the appellants, ensuring adherence to the principles of natural justice. The decision to remand the case underscored the importance of addressing legal contentions comprehensively for a fair adjudication.
In conclusion, the judgment focused on the necessity of detailed findings and a comprehensive assessment of legal submissions in tax matters to ensure procedural fairness and adherence to legal principles. The remand for a fresh consideration highlighted the significance of providing reasoned decisions in line with natural justice principles.
-
2001 (5) TMI 779
The Appellate Tribunal CEGAT, New Delhi upheld the extension of capital goods credit under Rule 57Q to various electrical items, despite Revenue's argument that they are not machines. The Tribunal referred to previous decisions supporting the inclusion of such items that supply electricity to machines used in manufacturing. The Tribunal upheld the decision of the Commissioner (Appeals) and rejected the Revenue's appeal.
............
|
9911796707
