|
Advanced Search Options
Case Laws
Showing 201 to 220 of 1237 Records
-
2014 (3) TMI 1039
Pre-deposit of duty - interest and addition penalty of identical amount stands imposed - invoking the longer period of limitation - whether printing and lamination on plastic film amounts to manufacture? - Held that:- The activity of printing and plastic coating does not amount to manufacture. During the course of arguments, it is asked from the learned D.R. regarding the use of plain poly films rolls. The query was answered that the same can be used as packing material. In this case, as per the learned AR there is no change in the use of goods after printing and lamination. Therefore, the issue whether the activity of printing and lamination amounts to manufacture or not is to be considered at the time of final hearing as there was contrary decisions. I do agree with the contention of the learned Advocate that when there are contrary decisions on the issue, whether the activity of printing/lamination amounts to manufacture or not, relying on the decision of this Tribunal in the case of Maharashtra Seamless stay is to be granted. Therefore, the applicant has made out a case of waiver of pre-deposit but as learned Counsel for the applicant at the time of hearing their stay application before the referral Bench has offered for making further deposit of ₹ 20 lakhs in addition to ₹ 40 lakhs already deposited, therefore, I agree with the view of learned Member (Judicial) directing the applicant to make pre-deposit of ₹ 20 lakhs
-
2014 (3) TMI 1038
Imposition of penalty - Second Appeal filed by the petitioner against the assessment order was pending - Held that:- imposition of penalty can be done only after the assessment order had attained finality. So long as the Second Appeal is pending, in law, the assessment order has not attained finality. Therefore, the concerned authority is directed not to precipitate the penalty proceedings till the Second Appeal preferred by the petitioner is decided one way or the other. - Decided in favour of petitioner
-
2014 (3) TMI 1037
Penalty levied under section 271(1)(c) - claimed deduction on prior period expenses - Held that:- The Tribunal in the quantum appeal relating to assessment year 2004-05 has remitted the issue of prior period expenses back to the file of the Assessing Officer. In view thereof, we delete the levy of penalty under section 271(1)(c) of the Act on the said.
Disallowance of allowance of set off of brought forward losses/depreciation in the hands of the assessee - Held that:- We find no merit in the stand of authorities below in holding that the assessee by furnishing the said details had furnished inaccurate particulars of income specially in view of the note appended to the computation of income under which it has been declared that the said figures of brought forward losses had been worked out after accounting for the claim of sales tax subsidy for the earlier year on the basis of the orders of the Tribunal. No doubt the assessee had revised its claim of brought forward losses in assessment year 2003-04 in the revised return filed for the said year, but that in itself would not tantamount to furnishing of inaccurate particulars of income by the assessee. Accordingly, we direct the Assessing Officer to delete penalty levied under section 271 (1) (c) of the Act on the said non allowance of set off of brought forward losses/depreciation in the hands of the assessee
Assessability of sales tax subsidy - Held that:- No merit in holding the assessee to have furnished inaccurate particulars of income in respect of such debatable issue. The assessee is not exigible to levy of penalty under section 271(1)(c) of the Act on the aforesaid treatment of sales tax subsidy as revenue in the hands of the assessee and we uphold the order of the CIT (Appeals) in directing the Assessing Officer to delete the same
Disallowance made under section 36 (1) (iii) of the Act on account of disallowance of interest paid on secured loans being relatable to interest free advances made by the assessee - Held that:- Following the parity of reasoning in respect of the treatment to sales tax subsidy and the question of law pending adjudication before the Hon'ble Supreme Court of India, we confirm the order of the CIT (Appeals) in holding that in view of the debatable issue raised the assessee cannot be held to have furnished inaccurate particulars of income and hence not exigible to levy of penalty under section 271(1)(c) of the Act.
Disallowance in respect of excess depreciation claimed by the assessee on generator - Held that:- Where there is variance in the rates of depreciation to be allowed on the asset, the issue at best is debatable and such disallowance does not warrant levy of penalty under section 271 (1) (c) of the Act. However, the claim of the additional depreciation on the said asset by the assessee was both incorrect and misconceived, as there is no provisions of allowance of additional depreciation on such asset during the period under consideration. The assessee has made a false claim of additional depreciation and the assessee is exigible to levy of penalty under section 271 (1) (c) of the Act on such wrong claim of depreciation.
Addition on account of recomputation of deduction under section 80IA - Held that:- In the quantum appeal filed by the assessee, the Tribunal (supra) vide para 9 at pages 4 and 5 of the order held that the misc. income claimed by the assessee was not derived from any industrial undertaking. The assessee was held not entitled to claim deduction under section 80IA of the Act in respect of such misc. income following the ratio laid down by the Hon'ble Supreme Court in Liberty India Vs. CIT [2009 (8) TMI 63 - SUPREME COURT ]. The assessee having claimed deduction under section 80IA of the Act on the aforesaid misc. income by including the same in the eligible profits of business and its denial being debatable does not tantamount to furnishing of inaccurate particulars of income by the assessee and making it exigible to levy of penalty under section 271(1)(c) of the Act.
Interest income included in the profits of business while computing the deduction under section 80IA - Held that:- In the facts of the present case as pointed out in paras hereinabove, the claim of the assessee cannot be said to be bonafide once the issue had been settled by the Hon'ble Supreme Court in Pandian Chemicals Ltd. (2003 (4) TMI 3 - SUPREME Court ). Thus the assessee is liable to levy of penalty under section 271(1)(c) of the Act on such reworking of deduction under section 80IA of the Act on interest income. Accordingly, we uphold the order of the CIT (Appeals) in this regard.
Income included by the assessee as being derived from the industrial undertaking was the insurance claim - eligible for the deduction under section 80IA - Held that:- treatment of the receipts from insurance claim being includible or not being includible in the profits of business, while computing deduction under section 80IA of the Act i.e. whether the same is derived or not derived from the industrial undertaking, makes the issue debatable issue and additions on such debatable issue can not tantamount to furnishing of inaccurate particulars of income as held by us in paras hereinabove. The claim of the assessee at best could be said to be debatable claim which does not make the assessee exigible to levy of penalty under section 271 (1) (c) of the Act.
Deduction allowable under section 80HHC - Held that:- Where the assessee has furnished complete particulars in respect of its items of income as detailed above merely because the said items of income were held to be not eligible for deduction under section 80HHC of the Act and the said deduction was recomputed by excluding 90% of the said income from the eligible profits, the said recomputation would not tantamount to furnishing of inaccurate particulars of income making the assessee exigible levy of penalty under section 271 (1) (c) of the Act. Accordingly, we direct the Assessing Officer to delete penalty levied under section 271 (1) (c) of the Act on the recomputed deduction under section 80HHC of the Act.
Thus penalty under section 271(1)(c)is upheld on Additional depreciation on asset and Deduction under section 80IA of the Act on interest income
-
2014 (3) TMI 1036
Eligibility for deduction under section 80IB - additional constructed area is not eligible for deduction under section 80IB as per CIT(A) - Held that:- As seen from the permission granted by the GHMC the original sanctioned plan was for cellar, stilt + 9 floors consisting of 9763.76 sq. meters. The revised plan was also stated to be cellar, stilt + 9 floors + pent house. We are unable to understand whether addition of only pent house will increase the space of built up area by 6543.84 sq. meters or there are any other increase in the area of additional buildings constructed.
Since the plans are not placed on record, we are unable to give any finding on this. Moreover, the BPS scheme was applicable only to the applications made on before 31-03-08. The plans were approved only in July 2007. Payments for penalty were made later as can be seen from copy of approval placed on record. Since revised plans were not placed on record we are unable to decide issue only on legal principles. The A.O. is directed to examine the original plans, revised plans and examine whether the deduction under 80IB is eligible for revised plan.
In case of area of flats have changed, to verify whether the constructed apartments are within the norms prescribed under section 80IB(10). Needless to say that balconies and common areas are not to be considered as part of ‘flat area’ as per the decisions of the Coordinate Bench on the issue. However, the pent house constructed and the additional space for which revised plans were taken should be examined whether the project itself is eligible for 80IB (10), on which there is no finding from the A.O. or by the CIT(A) in the orders. Not only that as seen from the P & L account assessee is still carrying closing stock of more than ₹ 4 crores, whereas sales during the year was ₹ 6.24 crores. Whether assessee hass continued to claim 80IB(10) in later year also on the balance of constructed area required to be examined, keeping in mind the method of accounting followed. As AO estimated income for non production of books of account, we are of the opinion that these aspects also require examination.
-
2014 (3) TMI 1035
Disentitlement of grant of bail - Evasion of customs duty by carrying 18kgs of gold while traveling - Under Section 135 of the Customs Act, 1962 - Held that:- the respondent-accused persons are previous offenders contended by the petitioners but it was not disclosed in which cases they are involved and also one of the main accused is seriously handicapped with 61% of disability. Whether retracted confessions are true or not, is an aspect which is required to be considered at trial and is not to be looked into at this stage to cancel bail granted to respondent-accused persons. Custody of accused persons in a case like the instant one is not to be measured in days but it has to be seen whether the grant of bail would hamper the investigation and if it is found to be so, then bail is not to be granted in such cases. The gravity of offence is a valid consideration to be kept in mind while granting or refusing bail and it does not really justify grant of bail at initial stage of investigation but since impugned order does not border on perversity, therefore, it is being not interfered with. However, grant of bail to respondent-accused at initial stage of investigation is deprecated in the facts and circumstances of this case. - Petition disposed of
-
2014 (3) TMI 1034
CENVAT Credit disallowed - CREDIT availed on Goods Transport Agency output services for the period May, 2005 to March, 06 which the appellant had availed after taking 75% abatement under Notification No. 32/2004-ST read with Notification No. 12/2003-ST as amended - taking of credit on the TR-6 challan - Held that:- We hold that the appellant have rightly availed CENVAT Credit being an amount paid towards Goods Transport Agency service. We further hold that the appellant is entitled to CENVAT Credit taken on the basis of TR-6 challan, which is a notified documents for availing credit and being a procedural issue, will apply retrospectively. We further hold that the input service like Courier service, Xerox service and rent-a-cab operator service are input services in relation to business of the appellant as a manufacturer and service provider and as such the appellant has rightly availed the CENVAT Credit on the input. Thus, the impugned order is set aside. The appeal is allowed with consequential benefit.
The appellant has admittedly paid 50% of the impugned demand by way of pre-deposit. As such we direct the adjudicating authority to refund the amount within a period of two months from production of a copy of this order with interest as per rule. - Decided in favour of assessee
-
2014 (3) TMI 1033
Demand of erroneous refund - pre-deposit of duty demand, interest and penalty - Held that:- On going through the Chart given in Para 7 of the show cause notice regarding month-wise percentage of duty payment through PLA, it is seen that though during most of the months, the same has been varying from 38% to 41%, in some months - March, 2011, June, 2011 and March, 2012, the same was 2% and 0%. Prima facie, from this data, it is clear that even if during certain months, lesser amount of duty was paid through Cenvat credit resulting in higher payment of duty through PLA and higher quantum of exemption, in subsequent months, it got compensated by much higher percentage of duty payment through cenvat credit varying from 98% to 100% and during those months, the appellant have availed almost negligible exemption. In view of this, this has to be treated as revenue neutral case and as such, there is merit in the appellant’s plea that there was no intention to avail higher quantum of exemption. As regards, duty demand of ₹ 18,18,507/- on the value of the corrugated boxes applied by M/s. Vishal Industries free of charges, we are of prima facie view that since tin containers were marketable as such, the cost of corrugated boxes supplied by M/s. Vishal Industries would not be includible in the assessable value. Thus, on both the counts, M/s. Vinayak Industries have prima facie case in their favour.
As regards, M/s. Vishal Industries, penalty has been imposed on them under Rule 26(1) of the Central Excise Rules under which penalty is imposable on a person, who deals with the excisable goods in the manner specified in this Rule knowing that the same were liable for confiscation. In this case, none of the offences to which Rule 26(1) of the Rules applies, had been committed by M/s. Vishal Industries. Therefore, we are of the prima facie view that imposition of penalty on them under Rule 26(1) of the Central Excise Rules, 2004 was not called for and as such, M/s. Vishal Industries also have strong prima facie case in their favour.
In view of the above discussion, the requirement of pre-deposit of duty demand, interest and penalty by M/s. Vishal Industries and the requirement of pre-deposit of penalty by M/s. Vishal Industries is waived for hearing of their appeals and recovery thereof is stayed till the disposal of the appeals. Stay applications are allowed.
-
2014 (3) TMI 1032
Refund claim - Reversal of cenvat credit at the time of getting the refund claim - Whether reversal of cenvat credit at the time of getting the refund claim amounts to non-availment of cenvat credit if the appellant is 100% Export Oriented Unit, exporting the goods manufactured and not clearing it in Domestic Tariff Area- Held that: The appellant is 100% EOU and not clearing any goods in DTA and, therefore, there is no possibility for them to avail the cenvat credit. Further, they have reversed the cenvat credit before the refund was actually granted to them. Therefore,in view of the decision of the Hon’ble Allahabad High Court in the case of Hello Minerals Water (P) Ltd. vs. UOI reported in 2004 (7) TMI 98 - ALLAHABAD HIGH COURT and Mumbai Tribunal’s decision in the case of Sagar Twisters vs. CCE, Mumbai reported in 2005 (5) TMI 144 - CESTAT, MUMBAI, the appeal is allowed. - Decided in favour of appellant
-
2014 (3) TMI 1031
Determination based on the books of accounts - whether the rejection of books of account is proper? - Held that:- Held that:-Findings of the Tribunal in the case of Hitesh Mehta [2014 (7) TMI 836 - ITAT MUMBAI] deserves to be followed. The matter should go back to the file of the AO to pass a fresh order, for rejecting the books of account, the AO has not given any valid reasons as no specific defect has been pointed out in. the books of account, the AO should go through the books for determining the income on the basis of books accounts – AO has to bring on record specific evidence or defect to prove falsity of books of account as no falsity has been proved in the assessment order passed by the AO – revenue has to provide all the details and material on which basis the addition have been made earlier - the AO is directed to provide the copies of all information on which basis, the AO wanted to made additions in the hands of the assessee and the matter is remitted back to the AO for fresh adjudication – Decided in favour of Assessee for statistical purposes.
-
2014 (3) TMI 1030
Disallowance u/s 14A - Held that:- Substantial questions of law as proposed and formulated are concluded by the Judgment of this Court in the case “Godrej and Boyce Mfg. Co. Ltd. Vs. Deputy Commissioner of Income Tax and another” [2010 (8) TMI 77 - BOMBAY HIGH COURT ] held that no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to such income which does not form part of the total income under the Act, by virtue of the provisions of Section 14A(1) - The company is chargeable to tax on its profits as a distinct taxable entity and it pays tax in discharge of its own liability and not on behalf of or as an agent for its shareholders. In the hands of the shareholder as the recipient of dividend, income by way of dividend does not form part of the total income by virtue of the provisions of Section 10(33). Income from mutual funds stands on the same basis - The provisions of sub sections (2) and (3) of Section 14A of the Income Tax Act 1961 are constitutionally valid - The provisions of Rule 8D of the Income Tax Rules as inserted by the Income Tax (Fifth Amendment) Rules 2008 are not ultra vires the provisions of Section 14A, more particularly sub section (2) and do not offend Article 14 of the Constitution - the Assessing Officer is duty bound to determine the expenditure which has been incurred in relation to income which does not form part of the total income under the Act. The Assessing Officer must adopt a reasonable basis or method consistent with all the relevant facts and circumstances after furnishing a reasonable opportunity to the assessee to place all germane material on the record.
-
2014 (3) TMI 1029
Expenditure on account design and drawing and fee paid to the foreign technician - characterization as a Revenue expenditure OR capital expenditure - Held that:- As decided in assessee's own case [2010 (9) TMI 121 - DELHI HIGH COURT ] both the issues or questions of law are covered against the Revenue treating the nature of expenses as revenue in nature. - Decided in favour of assessee
-
2014 (3) TMI 1028
Disallowance made under Section 40(a)(i) of commission payment = Applicability of section 9 - commission payment made for services rendered in India - Held that:- Tribunal, after perusal of the entire record including the agreement in question, pointed out that the assessee was paying similar commission in earlier years and there was no such disallowance. The issue of T.D.S. never arises as the said person has no permanent establishment in India. The amount was not taxable as the services were not rendered in India. In para 6 of the order passed by the Tribunal, it has referred to the appointment order and also the entire record. The nature of the services rendered have also been considered. It is in these circumstances that there was no conclusion that the matter does not fall within the purview of the Explanation 2 and as urged before us. These are matters fully covered by the same, that the services rendered are of the nature, namely, looking after sales, creditworthiness of buyers and overseeing the payment to assessee in the business of export of cycle and cycle parts. In such circumstances, the concurrent findings of fact are consistent with the material produced including the agreement. They do not give rise to any substantial question of law, much less, as framed in the present appeal. - Decided against revenue
-
2014 (3) TMI 1027
Deduction u/s.80IB disallowed - as per revenue the assessee was not having factory license before it started manufacturing activities - Held that:- The basis for disallowance of deduction u/s.80IB was not that the production had not been started but the controversy was that the license was issued after the close of the said financial year; hence, the assessee’s claim of start of manufacturing activity was allegedly incorrect. It is worth to mention at this juncture that in assessee’s own case for A.Ys. 2005-06 and 2006-07, after appreciation of all the facts and evidences, the Respected Co-ordinate Benches have decided this controversy in favour of the assessee. Therefore, while deciding an appeal of the Revenue for subsequent year, i.e., 2007-08 the judicial propriety requires to follow the earlier precedents of the Respected Co-ordinate Benches pronounced in assessee’s own case. Firstly on this basis, we hereby affirm the relief granted by the learned CIT(A).
What is essential is that the assessee should manufacture or produce an article or thing before the prescribed date. It was held that if there is any violation of any provision of any other statute then the assessee has to explain the same to the authorities implementing those statutes but the same could not be the basis of denial of benefit u/s. 80IB of the IT Act. On this reasoning as well we hereby uphold the view of learned CIT(A) in deleting the disallowance. - Decided in favour of assessee
-
2014 (3) TMI 1026
Penalty u/S 271AAA - Held that:- Revenue has not asked the assessee to disclose the manner in which such income was earned. In any case once the income is surrendered during the course of search u/s 132(4) it can be safely assumed that during discussion the assessee must have disclosed the manner. In any case we find force in the submissions of the Ld. Counsel for the assessee that if the explanation of the assessee has been accepted for some part then same manner should have been accepted for the whole of the amount. In any case the Ld. CIT(A) has considered all these issues in detail and the D.R. for the Revenue has not referred to any material or decision which can controvert the findings of the CIT(A). In the following cases which have been relied on by the Ld. Counsel for the assessee which was clearly held that penalty is not leviable. - Decided in favour of assessee
-
2014 (3) TMI 1025
Jurisdiction of High Court - Held that:- Matter relates to Diu & Daman territories, and therefore, under section 269 (vi) of the Income Tax Act, the same will fall under the jurisdiction of High Court of Bombay.
Accordingly, Tax Appeal is disposed of as not maintainable before this Court with a liberty to the Revenue to approach before the High Court of Bombay.
-
2014 (3) TMI 1024
Disallowance u/s 40(a)(ia) - Held that:- Admittedly, the assessee is liable to deduct and pay tax on the royalty paid to Sea Food Exporters Association of India. It is also an admitted fact that the assessee has not deducted tax while making the payment. The assessee now claims that the recipient of the amount, viz. Sea Food Exporters Association of India has paid the tax, therefore, there cannot be any disallowance u/s 40(a)(ia) of the Act in view of Second Proviso to section 40(a)(ia) which was introduced by Finance Act, 2012 with effect from 01-04-2013.
The Kerala High Court in M/s Prudential Logistics And Transports vs ITO [2015 (2) TMI 847 - KERALA HIGH COURT] while examining the provisions in Second Proviso to section 40(a)(ia) found that the benefits conferred by Proviso to section 40(a)(ia) is not available for the assessment year 2007-08. In other words, Second Proviso to section 40(a)(ia) operates prospectively and not retrospectively. In view of this judgment of the Kerala High Court in M/s Prudential Logistics and Transports (supra), this Tribunal is of the considered opinion that the benefits extended by Parliament by Finance Act, 2012 with effect from 01-04-2013 by Second Proviso to section 40(a)(ia) cannot be applicable to the assessee for the assessment year under consideration. Therefore, we do not find any infirmity in the order of the lower authority. Accordingly, the same is confirmed. - Decided partly in favour of assessee
-
2014 (3) TMI 1023
Addition under Section 68 - ingenuity of gift - Held that:- There is contradiction in respect of mode of receipt or payment. Though the payment was received by demand draft, she deposed that it is received by cheque. She was unaware about the business / profession of the donor. She stated that the money received was utilised for purchase of flat in 'Sripati Arcade', Nana Chowk, Mumbai which flat was valued at ₹ 2.73 crores. The Assessee, therefore, could not give a satisfactory explanation. It could not be said to be a simple case of gift and born out of natural love and affection. The Assessing officer has noted that the husband of the assessee is in the business of metal import and amount claimed to have been received as a gift has been remitted by M/s.Sun Metals Casting LLC, which is a company in metal trading in Sharjha (UAE). Therefore, this was the business relation with the husband and as a result of that the remittance came. In such circumstances, this would not be a case of genuine gift. It is in that context that all the three Authorities have concurrently found that the Appellant – assessee has failed to establish the essential ingredients of gift. They have not probed the gift or the aspect of natural love and affection as contended by the learned Counsel. While examining the details and scrutinising the necessary documents which have been given by the Assessee that the Authirities have concurrently found that the whole transaction was camouflage of business relation between assessee's husband and the alleged donor - Decided against assessee
-
2014 (3) TMI 1022
Deduction u/s 10B denied - Held that:- CBDT vide Circular No. 1/2005 had clarified that an undertaking set up in Domestic Tariff and which derives profit from export of articles or things or computer software manufactured or produced by it shall be eligible for deduction u/s. 10B of the Act on getting approval as 100% EOU and in the year of approval the deduction shall be restricted to the profits derived from exports from and after the date of approval of the DTA unit as 100% EOU. CIT(A) has also given a finding that Assessee was granted 100% EOU status with effect from 1/11/2002 and its claim for deduction u/s. 10B would be eligible for the period 1/11/2002 to 31/03/2003. The aforesaid finding of CIT(A) has not been controverted by Revenue by bringing any contrary material on record. With respect to various income on which Assessee has claimed deduction, we find that Assessee has submitted the details of other income which is also reproduced hereinabove. The ld. A.R. has submitted tht the issue with respect to income from DEPB Duty Draw Back, DEPB Duty Draw Back difference are covered against the Assessee in view of the decision of Apex Court in the case of Liberty India (2009 (8) TMI 63 - SUPREME COURT ). Thus the Assessee would not be eligible for deduction under section 10B on the aforesaid items
With respect to other incomes other than those covered against the Assessee, it is submitted that the same are covered in favour of Assessee by the various decisions cited hereinabove. From the table it is seen that Assessee has bifurcated the income into 2 periods up to the period of granting of EOU status and subsequent to it. We are of the view that these factual aspect needs verification at the end of A.O. We therefore remit the issue to the file of A.O. for fresh examination of the claim of Assessee , the bifurcation of income into 2 periods in the light of the decisions cited by Assessee and thereafter decide the issue as per law and after giving a reasonable opportunity of hearing to the Assessee. The Assessee shall be at liberty to furnish additional evidence before A.O. Thus this ground is allowed for statistical purposes.
-
2014 (3) TMI 1021
Transfer pricing adjustment - Held that:- The demand is mainly due to the Transfer Pricing Adjustment made by the AO. We further find that most of the issues agitated before the Tribunal have been decided in favour of the assessee,that adjustment of ₹ 7.5 Crores has to be carried out by the AO.Considering the facts and circumstances of the case, we are of the opinion that it is a fit case for staying the demand.Accordingly,demand is stayed till the disposal of appeal by the Tribunal or for a period of six months whichever is earlier. AO is directed not to make any adjustment except for the amount of ₹ 7.5 Crores for which proceedings are pending before him till today. Registry is directed to fix the hearing of the case on 16.06.2014, as early hearing matter.As both the parties have been informed about next date of hearing in the court room, no separate notice of hearing will be issued.
-
2014 (3) TMI 1020
Claim of depreciation holding it as application of income on stated charitable objects - Held that:- The issue in appeal is squarely covered in favour of the assessee by various decisions of the co-ordinate Bench of this Tribunal and in fact Commissioner of Income Tax (Appeals) followed those decisions of the Tribunal and allowed the claim of the assessee.
On going through the above findings of the Commissioner of Income Tax (Appeals), we find that this issue has been decided in favour of the assessee following various decisions of the co-ordinate Bench of this Tribunal. Therefore, we do not find any infirmity in the order passed by the Commissioner of Income Tax (Appeals) in allowing the claim of the assessee and uphold the same.
............
|
9911796707
