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2022 (10) TMI 660 - HC - Income TaxDisallowance of claim for expenses - difference between the actual and the declared amounts under all the heads is on the higher side - Tribunal was justified in rejecting the claim of appellant that the assessing authority has not rejected the audit report and final statement of accounts based on valid materials? - HELD THAT:- The documents/ accounts are at variance with the declaration made by the assessee in the returns. The difference between the actual and the declared amounts under all the heads is on the higher side. The assessing authority gave an opportunity to justify the claim under the respective heads. It is at this juncture the appreciation of the issue comes for our consideration. The resistance to the notice by the assessee is very informal. As already noted, the said reply did not convince the assessing authority. No exception to the findings of fact recorded in this behalf is argued. We have independently perused the conclusions recorded by the AO, CIT (Appeals) and the Tribunal. What arises first for consideration of this Court is whether an error is committed by the Tribunal and the Authorities under the Act; then, this Court can embark upon the merits of the matter. The assessee failed to demonstrate any error in law for our examination. Under those circumstances, having independently considered the issue, we are of the view that the orders under appeal do not warrant our interference. Substantial questions of law framed are unavailable. The findings recorded are simple findings of fact. Questions are answered in favour of the Revenue and against the assessee.
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