TMI Blog2012 (5) TMI 86X X X X Extracts X X X X X X X X Extracts X X X X ..... eleted the addition made by the AO on account of investment made by the three partners with the assess firm – Held that:- The three partners are income tax assessees and copies of their returns of income were furnished during the assessment proceedings - contribution made by the partners shown in their respective returns could not be said to be from unknown sources of income - in favour of the assessee. Disallowance on account of the purchases of the material and hire charges of the dumper/tractor – Held that:- assessee never produced before the Assessing Authority proof of genuine transactions despite of giving repeated opportunities – finding of no illegality or perversity in the observations made by Authorities as finding of facts rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... chases of the material and Rs.75.000/- on account of the hire charges of the dumper/tractor which decision is against sections 28 and 29 and section 37(1) of the Income Tax Act, 1961. ii) That whether under the facts and circumstances of the case the inference drawn by the Tribunal about the genuiness of the transactions considering the totality of the circumstances is perverse and the order need to be quashed. iii) That whether the Tribunal was justified in giving a finding that sufficient opportunity was given to the appellant in the assessment proceedings and appellant proceedings and there was no violation of the principles of natural justice in upholding the necessary disallowance. Brief facts inter-alia are that Assessee/partnersh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ns made by all the three Authorities. Concurrent finding of facts recorded by all the three Authorities are based on logic and does not require interference, therefore, substantial questions of law as suggested by the assessee/appellant do not require any adjudication and stood answered by concurrent findings of fact. The A.O and CIT (A) have observed that assessee has claimed expenses in the months of February and March, 1993 for which payment was shown having been received in the month of April, 1994, therefore, since payments were submitted in the months of February and March, 1993, hence, amount received against the bills submitted in February, March, 1993 should have been taken into account in the previous year for the reason that th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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