9911796707
TMI Blog1985 (11) TMI 88X X X X Extracts X X X X X X X X Extracts X X X X ..... for which the previous year ended on 31-3-1978. The assessee filed his income-tax return for this assessment year on 17-1-1979 disclosing an income of Rs. 1,02,790 and an agricultural income of Rs. 1,000. The ITO proposed to tax the assessee on an income of Rs. 11,63,660. As the variance between the returned income and the income on which the assessee is proposed to be assessed is more than Rs. 1 lakh, the ITO forwarded the draft order dated 13-3-1981. It was issued to the assessee on 17-3-1981. The objections to the draft order were filed on 31-3-1981. Both the draft order and the objections were sent to the IAC. After receiving the draft as well as the objections the IAC posted the proceedings for enquiry on 19-9-1981. The notice of that enquiry reached the assessee on 23-9-1981. Directions under section 144B were issued on 25-9-1981, without hearing the assessee, approving various additions and disallowances proposed by the ITO. The IAC directed the ITO to complete the assessment accordingly. In pursuance of those directions of the IAC, the ITO completed his assessment order dated 26-9-1981. 3. Aggrieved against the assessment order dated 26-9-1981, the assessee preferred an ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Addl. ITO v. Ponkunnam Traders [1976] 102 ITR 366 the assessment should have been annulled. The Tribunal dismissed this plea of the assessee as untenable in view of the following decisions : Banarsidas Bhanot & Sons v. CIT [1981] 129 ITR 488 (MP), H.H. Maharaja Raja Pawer Dewas v. CIT [1982] 138 ITR 518 (MP) and Third ITO v. Shivaji Park Gymkhana [1983] 4 ITD 462 (Bom.) (SB) and confirmed the order of the Commissioner (Appeals) dated 23-2-1982. After holding that the ratio of the Special Bench decision of the Tribunal in Shivaji Park Gymkhana's case fully applies to the facts of the present case, the Tribunal held as follows at the close of para 6 of its order : "... respectfully following the same we hold that the assessment order in the present case is not a nullity, that the failure of the Inspecting Assistant Commissioner to give a proper opportunity to the assessee of being heard is only a procedural irregularity and that the matter has to be restored to the Income-tax Officer for complying with the procedure under section 144B. The order of the Commissioner (Appeals) has only to be confirmed." Thus, by its order dated 17-11-1983, the Tribunal dismissed the appeal filed by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essment order is set aside. It is also the case of the assessee that the proceedings should freshly start with passing of a fresh draft order. Further, according to the assessee's counsel, when the proceedings came back for fresh start there was change of incumbent in the office of the ITO. So the successor ITO may choose to send the same draft or a different draft. According to the learned advocate, the old draft is dead and gone. He vehemently argued that Explanation 1(iv) to section 153 of the Act states that in a case where objections were filed over the draft assessment order the directions of the IAC under clause (iv) of Explanation 1 to section 153 should be received within 180 days from the date of forwarding the draft order, or in a case where no objections were filed for the draft, the assessment should be completed within 30 days of such forwarding. So, the argument of the learned counsel continued that the date of forwarding of the draft is a crucial date to determine the period of limitation. Applying the law to the facts of the case, the learned counsel argued that the draft order was passed under section 144B(1) and was issued to the assessee on 17-3-1981. Objections ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be set aside. He vehemently contended that the draft assessment order dated 13-3-1981 was not set aside. It is only the assessment order dated 26-9-1981 which was set aside, in order to facilitate correcting the irregularity which occurred in following the procedure under section 144B. In the submission of the learned departmental representative, sub-sections (1) to (4) of section 144B denote the stages of procedure to be followed one after the other. The assessment which would be completed on receipt of directions from the IAC under section 144B(4) is quite different and distinct from the draft order which would be passed by the ITO under section 144B(4). The ultimate assessment order which would be passed by the ITO under section 144B(4) may not conform to the draft order with regard to all, some or any addition proposed in the draft order because while giving directions the IAC may favourably consider the objections raised by the assessee to the draft. The irregularity has crept in while following the procedure under section 144B(4) inasmuch as opportunity to the assessee was not granted about his objections. In order to correct that irregularity, the assessment was set aside w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rections was bound by the directions given subject to carrying out those directions, he has the same powers as he had originally when making the assessment order under section 23..." 10. The view of the Andhra Pradesh High Court in Pulipati Subbarao Co. v. AAC [1959] 35 ITR 673 where it was held that the ITO's jurisdiction is restricted by the order of the AAC remanding the matter for fresh disposal was expressly dissented from by the Madras High Court. 11. The learned counsel for the assessee also relied upon the decision of the Madhya Pradesh High Court in Kundanlal Maru v. CIT [1982] 135 ITR 84 as well as the decision of the Kerala High Court in K.P. Moideenkutty v. CIT [1981] 131 ITR 356. So also he placed reliance upon the Gujarat High Court decision in Mrs. Meeraben P. Desai v. Union of India [1981] 130 ITR 922. 12. In reply the learned departmental representative submitted that the ratio of the above decisions do not apply to the facts of this case and they are quite distinguishable. 13. The learned counsel for the assessee also relied upon the following authorities to substantiate his plea that a mechanical order passed by the ITO and following the instructions of the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owered to add a new source of income in the fresh assessment. It is argued that the AAC's order remanding the case shall not be treated as one setting aside the entire order and remanding the entire proceedings for reconsideration by the ITO. Their Lordships did not accept this plea and they held : "... We are unable to read the order of the Appellate Assistant Commissioner as in any way limiting the scope of the ITO when he makes the fresh assessment order. Once the order of assessment is set aside it is open to the Income-tax Officer to consider the entire matter afresh and neither the order of the Appellate Assistant Commissioner in terms restricts the Income-tax Officer to consider the issue relating to the estimation of the income alone nor there is any warrant for reading such a restriction of the power either under section 251(1)(a) or under section 143(3) under which the Income-tax Officer makes a fresh assessment...." Lower down, no doubt there was an observation of the Madras High Court as follows : "... But if the order of assessment is set aside and the Income-tax Officer is directed to make a fresh assessment, we do not find anything in the provision of the Act whic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reservations about the second point decided by the Madras High Court when it observed 'in the instant case, it is not necessary for us to go into the later question to answer the question at hand'. In fact, in that case the scope of the powers of the ITO while passing fresh assessment orders was determined with reference to the scope of the remand order and the Madhya Pradesh High Court very much relied upon the Andhra Pradesh High Court decision in Pulipati Subbarao & Co.'s case which the Madras High Court dissented from. Therefore, the Madhya Pradesh High Court was not an authority for the proposition that once the assessment order is set aside no betters on the powers of the ITO can be put. In the facts of the case before the Madhya Pradesh High Court, when the assessment order was set aside no restriction over the powers of the ITO were imposed while making the fresh assessment order, whereas in the case before us the remand was specifically made only to set right the irregularity committed while following the procedure under section 144B and this was made very clear in the Tribunal's decision dated 17-11-1983, the operative paragraph of which is already extracted in this orde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... contended that clause (iv) of Explanation 1 to section 153 prescribes a limitation of 180 days from the date of forwarding draft assessment order to the date of giving directions by the IAC under section 144B(4). After a careful reading of clause (iv) of Explanation 1 to section 153, we are of the opinion that it prescribes a period for exclusion only. According to us, Explanation 1 comes into operation or comes to be considered only when certain period is sought to be excluded for the purpose of limitation. If in a given case the exclusion is not sought for and no enlargement of the period of limitation is required to be made out by the ITO it does not come to be considered at all. Even otherwise what all the provision says is that whatever period or, however much time might have been taken between the forwarding of the draft order and giving directions by the IAC, only 180 days would be allowed as a period entitled for exclusion for determination of the question of limitation. That is not the same thing as saying that direction given beyond 180 days from the date of service of the draft order is a nullity. That interpretation is not what is contemplated by clause (iv) of Explanat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s granted an opportunity to make the submissions before the ITO before passing a fresh assessment order dated 20-1-1984. The various decisions and authorities cited in support of this part of the assessee's contention are clearly distinguishable and do not apply to the facts of the present case and, hence, we need not consider them independently (or singularly). 19. The argument of the learned counsel that the assessment order dated 20-1-1984 is virtually an assessment passed by the IAC has no legs to stand in view of the fact that under section 144B(5) the statute itself make it obligatory on the part of the ITO to follow such and every direction issued by the IAC. So when the statute itself recognises that authority of the IAC no complaint can be made on the ground that the ITO did not apply his mind but only followed the orders of the superior officers and, hence, his own assessment orders are violative of principles of natural justice. For all the above reasons we are unable to hold that the assessment order dated 20-1-1984 is either null and void or vitiated by any illegality. Thus, the preliminary objection of the assessee fails. 20. Let us come to the merits of the case. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y tax. According to him, the property tax levied by the municipality was Rs. 371 and in support thereof he filed Annexure IX of the paper book. He submitted that though the property tax was Rs. 371 for 1982-83 but as revision of tax is taken for every five years it may be roughly taken as property tax obtained on 31-3-1978. He contended that the whole building was used only in the business of the assessee. At any rate even if it is held otherwise, there is no room to determine the annual value at Rs. 6,000. According to him it should not be more than Rs. 2,650, i.e., Rs. 371 x 100./14 24. The learned departmental representative contended on the other hand that according to the inspector's report which is furnished at page 3 of his compilation filed before this Tribunal, the annual value over the building bearing Municipal Nos. MC XIV/433, MC XIV/429 also should be added to the annual value determined over the building MC XIV/432, in order to come to the total annual value of the building and if the annual value is thus computed on all the three buildings marked, the annual value taken by the ITO at Rs. 6,000 is quite fair and just and is not liable to be disturbed. 25. After hear ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... raised was that the business increased considerably. It was urged by the learned counsel for the assessee that the profit derived in the accounting year relevant to this assessment year is more than Rs. 6 lakhs and, hence, making restriction to one-fourth of the expenses for the personal use of the car is more appropriate. 27. After hearing both sides, we feel we should accept this submission. We restrict the disallowance of one-fourth of Rs. 38,306. The assessee gets a relief of Rs. 3,192.50. 28. The next ground is with regard to the disallowance of Rs. 50,000 under section 40A(3) of the Act. The assessee made local purchases of shelled cashew kernels being 38,727.230 kgs. valuing Rs. 9,57,158.95. They include 1,134 kgs. of kernels valuing Rs. 50,000 purchased from a cashew worker called Shri Rajan. The amount was originally stated to have been paid through crossed cheque. It was subsequently turned out that the payment was made through bearer cheque No. 684331 dated 10-6-1977 drawn on Federal Bank Ltd., Quilon. In the beginning only bald address of Shri Rajan was furnished. He was not traced at that address. Summons were issued under section 131 of the Act. Those summons were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on the other hand, strongly tried to uphold the legality, validity, reasonableness and correctness of the orders of lower authorities by adopting their reasoning as part of his arguments for upholding the disallowance under section 40A(3). His reasons are : (1) the provisions of section 40A(3) are categorical, unambiguous and clear and so a case covered by those provisions should be disallowed; (2) the payment of Rs. 50,000 was made at one time to Shri Rajan through a bearer cheque but not either by a crossed cheque or crossed demand draft; (3) the payment is not covered by rule 6DD which forms an exception. Identity of the person and the truth of the payment were not established; (4) cashew kernel is neither an agricultural produce nor a forest produce nor a product of horticulture. So also it was not a payment made to a grower, cultivator or producer of such an article; and (5) it is not the case of the assessee that cashew kernels have been manufactured or processed without the aid of power in a cottage industry nor the payment was made in a town or village not served by any bank. 32. Thus, after hearing both sides, we express our inability to support the disallowance. While ar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rks 'addressee left'. Under those circumstances the Patna High Court held that the assessee had not only disclosed the identity of the creditors but also the sources of income. Here in this case also the bearer cheque dated 10-6-1977 given in favour of Shri K. Rajan was seized from the custody of the Federal Bank Ltd., Quilon. Copy of the cheque issued discloses that it was a bearer cheque and was issued for an amount of Rs. 50,000. The proceedings dated 6-3-1981 found at page 18 of the paper book filed by the department would disclose that the cheque was honoured and, therefore, there is sufficient evidence that the amount was paid to the person to whom the cheque was issued by the Federal Bank Ltd. As in the Patna High Court case, in the case before us we have to hold that Shri K. Rajan is not a fictitious person and that the primary onus which lay upon the assessee that he had paid Rs. 50,000 to Shri K. Rajan stood established. We, therefore, firstly hold that section 40A(3) does not apply to the payment made. Assuming without admitting that it does apply there is prima facie evidence to establish the genuineness of the payment and, hence, the disallowance under section 40A(3) c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee was consistently showing the yield of kernels from 36 to 40 lbs. per bag of cashewnuts as against the normal out-turn of 45 to 46 lbs. per bag. The assessee by his letter dated 29-9-1980 explained the reason for the low out-turn stating that the marketing federation entered into the cashew field for the first time in the accounting year in question. Since the officials of the corporation were new to this line the selection of raw nuts could not be done properly, resulting in the procurement of low quality and the exporters who took delivery of raw nuts from the federation ultimately suffered huge losses on account of the inferior quality of nuts supplied to them. It was also explained as the reason as to why other exporters were able to show better out-turn though they purchased raw nuts from the marketing federation. According to the assessee, the reason might have been that from out of the purchases made from the federation the proportion of African raw nuts might have been more or higher than that of the assessee in the case of other purchasers, Ultimately, it is explained that uniform out-turn in all cases cannot be obtained. It is also explained that inasmuch as purc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a reading of the impugned order of the Commissioner (Appeals), it would appear that he had accepted the tenability of the arguments (1) and (4) noted above. The argument Nos. (2) and (3) noted above were not accepted. The learned Commissioner (Appeals) held that the total bags of cashewnuts purchased were 16,823 of 80 kgs. each or 168 lbs. each. If suppression of 3 lbs. per bag is to be taken then the total quantity of suppression possible would be 50,469 lbs. But having accepted two out of the four arguments advanced and giving due credit to the substance of the arguments accepted, the learned Commissioner (Appeals) felt that, inasmuch as he has already upheld the additions of Rs. 50,000 under section 40A(3), he felt that the circumstances of the case would justify that retaining a further addition of Rs. 4.5 lakhs would be adequate and, therefore, he deleted the excess and, thus, partly allowed the appeal on this point. 36. Both the department as well as the assessee were aggrieved with this impugned decision of the learned Commissioner (Appeals). This department in its appeal contended that having found the probable suppression of out-turn at 50,469 lbs. the ITO should have sim ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... quantity was an outer limit of either suppressed turnover of yester years or the suppressed turnover of this year. He did not rule out the possibility that in this bogus purchases no suppressed out-turn of yester years was included. He also did not state how much quantity of suppressed out-turn of yester years was included in this total of 300 bags or 50,469 lbs. However, taking an overall view and having regard to the fact that this total of 50,469 lbs. include the suppressed out-turn of yester years also, he wanted to make an addition of Rs. 5 lakhs and inasmuch as he sustained an addition of Rs. 50,000 paid to one single party, viz., Shri K. Rajan and he disallowed the same under section 40A(3), he made an addition of Rs. 4.5 lakhs towards bogus purchases. 39. It is the case of the department that having found the bogus purchases at 50,469 lbs. the learned Commissioner (Appeals) should have simply multiplied its price at Rs. 15.77 per pound and should have arrived at the figure of Rs. 7,95,896.13. However, as the ITO made only an addition of Rs. 7,48,377 the learned Commissioner (Appeals) ought to have sustained the addition made by the ITO instead of reducing it from Rs. 7,48 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year 1978-79. The four cases are furnished below : Sl. No. Name of the assessee P.A. No. Quantity of kernels Value purchased (lbs.) 1. K.A. Karim & Sons 46-00-FN-3347/ 96,885 13,59,624 Kilikoll ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e facts were : the assessee was son of one Jaldu Venkata Subbarao who carried on business in timber at Masulipatnam. Shri Venkata Subbarao died on 22-6-1942. After his death the executors and trustees took over the management of his estate. During the assessment proceedings for the assessment year 1943-44, the examination of books of account of Masulipatnam timber depot produced by the executors revealed excess sales and closing stock of the value of Rs. 75,073. This amount was added to the book version of profit On the ground that it represents income in addition to the book profits. The contention before the AAC as well as the Tribunal on behalf of the assessee was that late Venkata Subbarao must be presumed to have purchased some stock and kept unaccounted for in the books of account and on this assumption a request was made that the addition should be deleted. Ultimately the argument pressed before the High Court was that the amount of Rs. 75,073 represented the value of stocks which were suppressed in previous years and, hence, they could not be regarded as the income of the year of account. The point at issue before the High Court was whether the amount of Rs. 75,073 represen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cts." Therefore, it is the case of the department that the normal yield of kernels was 45 lbs. per bag, whereas, the disclosed turnover was 36.26 lbs. per bag. When this is the position for 1978-79 the position obtaining with regard to assessment years 1976-77 and 1977-78 would also disclose that the out-turn shown by the assessee was not to the full extent. In the assessment year 1976-77, he disclosed an out-turn of 39.38 lbs. per bag whereas in 1977-78 he disclosed 39.56 lbs. per bag, Therefore, even in the immediately preceding two assessment years the disclosed out-turn was at least 5 lbs. less than normal out-turn. 40. It is further submitted by the learned counsel for the assessee that for the assessment year 1977-78, the assessee made a local purchase of 46,142 lbs. of kernels and in the assessment year 1979-80, he made similar purchase of 68,537 lbs. and both these purchases were accepted by the ITO without demur. Therefore, when that was the position there was no reason why 21,546 kgs. purchased during the accounting year relevant to the assessment year 1979-80 should be doubted on the ground that it is from local parties. 41. Having considered the arguments on both sid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... chases during the accounting year and so the average of Rs. 9 per tin should be applied to them. Thus, the total value works out to Rs. 32,399. Deducting the value of the stock already disclosed, viz., Rs. 8,391 a round sum addition of Rs. 24,000 was felt justified and made. The addition was confirmed by the Commissioner (Appeals). The order of the ITO which was confirmed by the Commissioner (Appeals) presumed two things---first, remaining out of the opening stock 5,390 tins were damaged ones and secondly, all the purchases made during the year were purchases at an average price of Rs. 9 per tin. To the extent any of the two presumptions go wrong the impugned order requires interference at our hands. Full details of purchases of tins during the accounting year as well as the opening stock of the tins at the beginning of the accounting year were furnished at Annexure XVI of the paper book filed by the assessee. As can be seen on 8-7-1977, 550 tins of third quality were purchased for a total of Rs. 572. So we feel justified that apart from 5,390 these 510 tins purchased during the accounting year and which are presumed to be remaining as closing stock also can justifiably be valued a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... would make us hold that Annexures XI to XIII cannot be safely relied upon, in any view of the matter as they were not considered by any of the lower authorities we are not prepared to consider them for the first time. Thus, in view of the fact that no confirmation letter was produced nor Shri Arumugam Swamy was examined before the ITO the addition of Rs. 30,000 towards unproved cash credit in our opinion is quite proper and legal. 46. The learned departmental representative no doubt relied upon the following decisions---Shankar Industries v. CIT [1978] 114 ITR 689 (Cal.), Gumani Ram Siri Ram v. CIT [1975] 98 ITR 337 (Punj. & Har.), Kale Khan Mohammad Hanif v. CIT [1963] 50 ITR 1 (SC) and CIT v. Orissa Steel Corpn. (P.) Ltd. [1983] 144 ITR 662 (Cal.) for the proposition that the onus is on the assessee to prove the cash credit. In view of the fact that we are deciding this issue in favour of the department and as there is no dispute regarding the burden of proof with regard to cash credit, we are not elaborately going into and discussing the facts for the ratio of the above decisions. 47. It is the case of the assessee that it had purchased 5,588 bags of African raw nuts. It made ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g local purchases for about Rs. 2 lakhs is not correct. Though he does not deny the amendment dated 7-9-1976, to the Central Sales Tax Act, he contends that the amendment was made public only in 1980 and it is not applicable for the purchases of kernels. Further, in the wealth-tax appeal of the assessee for the same assessment year, the AAC by his orders dated 26-7-1984 held that purchase tax liability on cashew kernels is an allowable deduction in the computation of the assessee's net wealth. Therefore, for the sake of consistency the learned Commissioner (Appeals) should have allowed the provision for purchase tax while computing the total income. The wealth-tax appellate order is provided as Annexure XIV in the paper book filed by the assessee. Paragraph 4 of those orders deals with purchase tax provision. A reading of that paragraph would reveal that the provision was allowed as a deduction. Shri Kochunni Nair, the learned advocate for the assessee, contended that purchase tax liability by itself was not done away with by the amendment dated 7-9-1976. What was dispensed with was purchase tax liability on purchase of kernels made in the course of export. He submitted that before ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me which must have been derived over two lorries at Rs. 5,000 as in last year after allowing depreciation of Rs. 5,000. The learned Commissioner (Appeals) confirmed it. 52. It is the present contention advanced on behalf of the assessee that the two lorries were used solely for business purposes and inasmuch as the business income was assessed the income from two lorries cannot be assessed independently. At page 5 of the paper book filed on behalf of the department, the department furnished copy of the letter dated 22-8-1980 addressed by the chartered accountant of the assessee to the ITO purporting to answer the queries raised in the ITO's letter dated 14-8-1980. The last paragraph of the letter disclosed both the query as well as explanation for it and they are as follows : "During the course of the examination of accounts you have raised some queries regarding the maintenance of an office by the assessee at Tuticorin. The details are as under : 1. The assessee is having a lorry booking office at Tuticorin. 2. The address of the same is 228, G.C. Road, Tuticorin-1. 3. Lorry KLU 5218 was purchased on 13-4-1978. 4. Lorry KLU 5947 was purchased on 7-12-1978. 53. The lorries w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; Rs. 1. Salary of persons said to be exclusively handling export business 11,850 2. Stationery &nb ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sp; ---------------------- The assessee claimed one-third of the total, viz., Rs. 72,551 as weighted deduction. The ITO disallowed weighted deductions on items 1, 2 and 4 from out of the above list of expenses, on the simple ground that they are not eligible for weighted deduction since they have been incurred within India and do not come under any of the clauses of section 35B(1)(b) of the Act. He allowed item No. 3. The foreign commission which is dealt with as item No. 5 in the list above is further analysed. The bifurcation of the payment of commission is as follows : Rs. 1. Richard Franco Agency Inc., New York &nbs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 6. In the appeal before the learned Commissioner (Appeals) he allowed weighted deduction even on commission payment made to Nutmeat Trading Co. That means he allowed weighted deduction on a further amount of Rs. 83,332 than the amount considered by the ITO. However, the learned Commissioner (Appeals) did not consider either items 1, 2 and 4 in the list given above or the amount of commission of 28,434 purported to have been incurred as commission payment to Gibbs Nathaniel of Canada. 56. In this second appeal the assessee contends that even on the abovesaid items it is duly entitled to weighted deduction. It is the contention of the department that the commission paid to Nutmeat Trading Co. was wrongly considered for weighted deduction. In Annexure XVII provided in the paper book on behalf of the assessee the total expenditure incurred on each and every item, the proportion of the total expenditure taken for claiming of weighted deduction and the eligible amount according to the assessee for weighted deduction were all furnished. As regards the first item the total of the expenditure towards salary of persons exclusively handling export business was Rs. 15,800. The assessee claime ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
