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Rich Capital & Financial Services Ltd. and others Versus Income Tax Officer 6 (2) Kanpur and others

2015 (7) TMI 617 - ITAT LUCKNOW

Reopening of assessment - assessment was reopened for assessment years 2001-02 to 2004-05 on the basis of the ADIT and DDIT report in which it has been stated that there are cash deposits in the bank accounts of the assessee - Held that:- Having relied upon the said report, the assessment was reopened under section 147 of the Act after issuance of notice under section 148 of the Act which was responded by the assessee. In assessment years 2000-01 to 2002-03, where the reopening was done on the s .....

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ssessment year, but it has been repeatedly held through various judicial pronouncements that rule of consistency must invariably be followed in Income-tax proceedings. If a particular view is taken in one assessment year, the same should be followed in other assessment year or succeeding assessment year unless and until contrary facts are brought on record. The order of the Tribunal in the immediately preceding years, where the reopening made on the same facts under section 147 of the Act was he .....

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ues on merit. - Decided in favour of assessee.

Addition on account of cash deposit in different bank accounts of the assessee - Held that:- Assessing Officer has made addition of the cash deposits in the bank accounts of the assessee having placed strong reliance upon the statement of Shri. Mukesh Rajani, Auditor of the assessee-company who deposed that the books of account of the company were produced before him in the form of computer printout. But this statement was never confronte .....

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of various persons from who cash was received, but it requires a proper verification by the Assessing Officer. In the light of these facts, we are of the view that this issue requires a fresh adjudication by the Assessing Officer and we accordingly set aside the order of the ld. CIT(A) and restore the matter to the file of the Assessing Officer with a direction to re-adjudicate the issue after affording an opportunity of being heard to the assessee. - Decided in favour of assessee for statistic .....

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ture. Since we do not find any infirmity in the order of the ld. CIT(A), we confirm his order on this issue.- Decided in favour of assessee.

Addition on account of advance as on 31.3.2006 and debited in the profit and loss account during the year - CIT(A) deleted addition - Held that:- The liability was crystalised in the impugned assessment year therefore, the assessee has rightly debited the said amount in the profit and loss account and there is no infirmity therein. Having agreed .....

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orders of the ld. CIT(A). 2. Since common issues are involved in these appeals, these were heard together and are being disposed of through this consolidated order. We, however, prefer to adjudicate them one after the other. I.T.A. Nos. 369 & 370/LKW/2014: BY THE ASSESSEE. 3. These appeals relate to assessment years 2003-04 and 2004-05. Besides challenging the addition made on merit, the assessee has raised a preliminary objection with regard to the validity of reopening of the assessment u .....

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is of the report, the assessment was reopened under section 147 of the Act after recording the following reasons:- From the perusal of records and information received from Dy. Director of Income-tax, Range-2, Kanpur vide his letter F. No. DDIT(Inv.)2/KNP/gift/RCFSI/07-08/1860 dated 21.3.2008, it is transpired that the ase has made cash deposits amounting to ₹ 2,03,72,500/- on different dates in Bank a/c No.62205046398,Bank A/c No.2633 and Bank A/c No.31126 maintained with Standard Charter .....

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0000 Cash 4-5-2002 15000 Cash 6-5-2002 135000 Cash 7-5-2002 15000 Cash 7-5-2002 30000 Cash 9-5-2002 200000 Cash 16-5-2002 6000 Cash 16-5-2002 215000 Cash 19-6-2002 250000 Cash 21-6-2002 20000 Cash 22-6-2002 100000 Cash 1-7-2002 250000 Cash 3-7-2002 10000 Cash 3-7-2002 250000 Cash 9-7-2002 450000 Cash 13-7-2002 25000 Cash 22-7-2002 100000 Cash 24-7-2002 75000 Cash 26-7-2002 168000 Cash 29-7-2002 15000 Cash Total 5129000 Bank A/C N0.2633 (Punjab National Bank, Shastri Nagar, Kanpur Date Of Deposit .....

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00 cash 10-5-2002 400000 cash 10-5-2002 380000 cash 15-5-2002 285000 cash 22-5-2002 400000 cash 4-6-2002 1000000 cash 6-6-2002 400000 cash 6-6-2002 600000 cash 7-6-2002 400000 cash 10-6-2002 500000 cash 25-6-2002 20000 cash 8-7-2002 1000000 cash 12-7-2002 250000 cash 17-5-2002 500000 cash 17-5-2002 5000 cash 20-8-2002 1500 cash 19-9-2002 10000 cash 30-10-2002 500000 cash 8-10-2002 150000 cash 9-10-2002 10000 cash 20-1-2003 52000 cash 20-1-2003 1000000 cash 20-1-2003 340000 cash 16-12-2002 80000 .....

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mpliance on 9.3.2009. It was specifically mentioned in the shown cause letter that failure on part of the assessee company would entail the under signed to initiate proceedings under section 147 of the Income-tax Act, 1961 for concealing the income to the extent of ₹ 2,03,72,500/-. On the date fixed for compliance, neither anybody attended nor any written submission was made on behalf of the assessee-company. In view of the above facts and the information in possession of the undersigned, .....

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in response thereto and the Assessing Officer has made an addition of ₹ 2,03,72,500/-, under section 68 of the Act having observed that cash deposit in the banks were not duly explained by the assessee. Our attention was also invited by the ld. counsel for the assessee, Shy Ajay Wadhwa, Advocate that for the similar reasons the assessment was also reopened for assessment years 2000-01, 2001-02 and 2002-03 and the validity of the reopening of assessment was questioned and the matter was re .....

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ve fads and circumstances of the case, rival submission and settled preposition of law by various Hon'ble High Court (supra), we are of the opinion that so far as present case is concerned the proceedings u/s 147 of the Act have been initiated solely on the directions of Asstt. DIT (investigation) /Addl DIT (investigation) and without there being application of mind of the AC) on any material except the direction to issue notice u/s 148 on the basis of facts that Addl DIT (investigation) and .....

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ited cash on different dates in Rank A/c No. C.A.-2633 with Punjab National Bank, Shstri Nagar, Kanpur during the F.Y. 1999-2000 relevant to A.Y. 2000-01 to the tune of ₹ 12914000/-. As such, the source of these Cash deposits amounting to ₹ 12914000/- leads to the conclusion that all these cash deposits are unexplained". 18. The noting, though it was not complete version of report received from Addl. DIT, yet raises an important issue when he says "source of these cash depo .....

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an assessment cannot be reopened solely on the basis of suspicion, the initiation of proceedings u/s 147 of the Act on the basis of this aspect also was not valid in the eyes of law. 19. In view of the above facts and circumstances we are of the opinion that initiation of proceedings u/s 147 of the Act, so far as allegation of escapement of income on account of unexplained deposits in bank is concerned, was illegal and bad in law and cannot be sustained. 19.1 From the above noting it is clear t .....

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racted hereunder for the sake of reference:- 6. We have heard the rival submissions. Shri Praveen Kumar, ld.CIT(DR) submitted that the ld.CIT(A) was not justified in following the order of the I.T.A.T., Lucknow-B, Lucknow dated 18.11.2009 passed in assessee's case for the assessment year 2000-01. Shri Praveen Kumar, Id. D.R. pointed out that while deciding the appeal for assessment year 2000-01, the Tribunal has ignored the decisions of the Hon'ble jurisdictional High Court in Brij Mohan .....

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ts of the present case. We further find that the reasons for re-opening the assessment are almost similar for both the years. The reasons recorded for reopening of the assessment for assessment year 2000-01 are as under : "A perusal of records and information received from Addl. Director of Income Tax(Inv.), Kanpur his letter F. No. Addl.DIT(Inv.)/Enquiry/Rich Capital/06-07/1135 dated 22.3.2007, it is transpired that the assessee has deposited cash on different dates in Bank A/c No. 13 with .....

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year i.e. ₹ 67163442/- in the year relevant to A.Y. 2000-2001 andRs.66288442/- in A.Y. 1999-00. This shows that the assessee has shown short receipt of interest of approximately ₹ 1100000/-in the A.Y. 2000- 2001. In view of the above facts and the information in possession of the undersigned, I am of the opinion that the assessee has concealed the income to the extent of ₹ 14014000/-(12914000 + 1100000/-)chargeable to taxforA.Y. 2000-01 has escaped assessment. Accordingly, iss .....

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and Bank a/c No.31126 maintained with Standard Chartered Bank, Kanpur, Punjab National Bank, Shastri Nagar, Kanpur and State Bank of India, Naveen Market, Kanpur respectively during the F.Y: 2001-02 "relevant to A.Y. 2002-03 as per following details:- Date of Deposit Amount Mode of deposit The Dy. Director of Income Tax (Inv)-2 Kanpur in his report had stated that the assessee had failed to prove the source of cash deposits in the above mentioned Bank Accounts. However in view of the above .....

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ncome to the extent of ₹ 3,16,07,800/-. On the date fixed for compliance, neither anybody attended nor any written submission was made on behalf of the assessee company. In view of the above facts and the information in possession of the under signed, I am of the opinion that the source of acquisition of the above cash deposits amounting to ₹ 3,16,07,800/- made in the above bank accounts of the assessee company, stands unexplained and thus the assessee company has concealed the incom .....

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says sources of these cash deposits lead to the conclusion that these credits were unexplained" and the issue so arises is as what was the material with respect to source with the AO (if, at all there was any). It was only doubt but not to have reasons to believe, meaning there by that if there was some material in respect of source, it was not sufficient for arriving at the conclusion that the deposits represented unexplained income. In other words the AO had just suspicion in his mind and .....

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above noting it is clear that there was no application of mind by Assessing Officer. 20. So far as second reasons for initiating proceedings u/s 147 is concerned the same as noted for reasons recorded is as under:- "From the perusal of P/L Account, it is seen that the assessee has shown interest at ₹ 500575/- as against the interest shown at ₹ 1573555/- in the A.Y. 1999-00. The Loans & Advances shown are more than the preceding year i.e. ₹ 67163442/-in the year releva .....

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be said to be valid, there being any detail as to the period for which the advances/loans were given or how much interest was received or could have received as per agreements, simply to doubt that interest received by the assessee in this year, being less than the interest received in the previous year as resulted in escapement of interest income of approximately 11 lakhs and that too only, because, total amount of allowance and advances at the end of this year was a little more than the amoun .....

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;Cf. CST v. Modi Industries Ltd., (1987) 67 STC 341(All), (ii) General Electric Company of India Ltd. V, STO (1974) 33 STC108 (All) (iii) M.L. Shukla v. STO, (1981) UPTC 396 (All) (iv) Kanhaiyalal Damodar DAs v. CST,(1989) 73 STC 404, 406 (All), (v) Smt. Kantamani Venkata Satyavathi v. ITO, (1967)64 ITR 516, 521 (AP); (vi) Madhya Pradesh Industries Ltd. V. Income Tax Officer (1965) 57ITR 637(SC) (vii) Bhimraj Panna Lal v. CIT, (1957) 32 ITR 289 (Pat), affirmed, (1961) 41 ITR 221(SC) (viii) M. Va .....

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nt framed on 20.12.2007, got vitiated. The reassessment completed on 20.12.2007 is therefore quashed being bad in law and void ab initio." 6.3 As we have already held that the facts and circumstances of the present case and the reasons recorded for re-opening the assessment are almost similar for both the years, therefore, the Id.CIT(A) was fully justified in following the decision of the Tribunal referred to above. 6.4 Now, we will discuss the decisions relied upon by the Id. D.R. 6.4 (i) .....

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cion and for making roving enquiries and since it is trite law that proceedings under Section 147 cannot be initiated either on the basis of mere suspicion or making fishing or roving enquiries, the initiation of proceedings under Section 147 of the Act on this ground was also illegal and bad in law. Thus, the above decision supports the view taken by the Tribunal in assessment year 2000-01. 6.4(ii) Shri Praveen Kumar, Id.D.R. also relied on the decision of the Supreme Court in the case of Raymo .....

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proceedings. We are not expressing any opinion on the merits of the case. The questions of facts and law are open to be investigated and decided by the assessing authority. The appellant will be entitled to take all the points before the assessing authority." In this case the Hon'ble Supreme Court has held that the commencement of re-assessment proceedings was valid. However, no decision was given on the issue of validity of re-opening. The questions of fact and law were left open to b .....

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decision of the Hon'ble Supreme Court rendered in the case of Raymond Woollen Mills (Supra) is of no help to the Revenue. 6.4 (iii) Shri. Praveen Kumar, Id. D.R. also relied on the decision of the High Court in the case of Abdul Khader Ahamed (Supra). This decision is also not applicable to the facts of the present case. In that case, the AO independently applied his mind to facts and recorded prima facie belief and reasons before issuing notice. The Hon'ble High Court held that it is n .....

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o help to Revenue's case. 6.4 In our considered view, the Id.CIT(A) was justified in following the order of the Tribunal passed in the assessee's case for assessment year 2000-01 and therefore, we are not inclined to interfere with the order of the Id.CIT(A) on this issue. 7. The ld. counsel for the assessee has further invited our attention to the fact that for assessment year 2000-01 the Tribunal has delivered its order on 18.11.2009 and this order was followed by the ld. CIT(A) in ass .....

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ere the reopening made on same facts and reasons was held to be invalid and the assessment framed consequent thereto was quashed by the Tribunal, the same order should have been followed in the impugned assessment year, as the reopening was done on the basis of same facts. The ld. counsel for the assessee has further contended that in the light of these facts, the reopening made in the impugned assessment year is invalid and the assessment framed consequent thereto deserves to be quashed. 8. The .....

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ter issuance of notice under section 148 of the Act which was responded by the assessee. In assessment years 2000-01 to 2002-03, where the reopening was done on the same facts, the Tribunal has held the reopening to be bad and invalid and quashed the assessment framed consequent thereto. Therefore, in the impugned assessment year, we do not find any justification to take a contrary view. 10. So far as the applicability of principle of res-judicata in Income-tax proceedings are concerned, we agre .....

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brought on record. The order of the Tribunal in the immediately preceding years, where the reopening made on the same facts under section 147 of the Act was held to be invalid by the Tribunal repeatedly in three assessment years, should be followed in the instant assessment year. We accordingly, following the said order of the Tribunal, hold that the reopening of assessment is bad and accordingly the assessment framed consequent thereto deserves to be quashed. Accordingly we annul the assessment .....

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counts of the assessee. The said addition was confirmed by the ld. CIT(A) as the assessee even could not produce the books of account. 12. Now the assessee is in appeal before the Tribunal and has placed reliance upon various judicial pronouncements in support of his contention that wherever books of account are lost or not available for any reason, the net profit of the assessee should be estimated. 1. P.K. Noorjahan, 155 CTR (SC) 509 ( 237 ITR 570). 2. Naim Ali Khan vs. ACIT, 86 TTJ 721 (Agra) .....

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IR was lodged with the Police Station on 22.11.2007. Shri. Ramsevak was found missing from the office since 22.11.2005 and a report was also lodged with the Police Station on 22.11.2005. Copies of the reports are available at pages 310 and 311 of the compilation of the assessee. 14. The ld. counsel for the assessee has further invited our attention that the Assessing Officer has made addition on the basis of the statement of Shri. Mukesh Rajani, Auditor of the assessee-company who has deposed th .....

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the form of computer printout in addition to maintenance of books of account on computer system and he accordingly held that the assessee has not intentionally produced the books of account. In this regard, the ld. counsel for the assessee has submitted that the assessee was not allowed to cross-examine Shri. Mukesh Rajani, therefore, his statement cannot be relied on against the assessee. The ld. counsel for the assessee has further contended that the assessee was engaged in the business of pro .....

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addition was made on account of cash deposit in bank accounts of the assessee. The ld. counsel for the assessee has further contended that in the light of the fact that the books of account of the assessee are not available, the Audit report submitted along with the return of income be accepted and addition made by the Assessing Officer may kindly be deleted. 15. In the alternative, the ld. counsel for the assessee has further contended that if any addition is called for, it can be only for inc .....

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The Assessing Officer has afforded number of opportunities to the assessee, but he did not produce the same. In the absence of any details of the borrowers and the books of account, the contentions of the assessee cannot be accepted and the Assessing Officer has rightly made the addition of the cash deposits. 17. Having carefully examined the orders of the lower authorities in the light of the rival submissions, we find that the cash books were never produced before the Assessing Officer either .....

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But no details of the borrowers, from whom money was received back in cash, were filed nor the books of account were produced before the Assessing Officer. The assessee has taken a plea that the books of account were maintained in the computer and the computer was destroyed by its employee, Shri. Ramsevak and in that regard he had lodged a complaint with the Police Station. Copy of the same is available at page 310 of the compilation of the assessee. Besides, the assessee has also made a complai .....

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ts audit in the office of the company. On the basis of this statement, the Assessing Officer has concluded that the assessee has been maintaining its books of account in the form of computer printout in addition to maintaining the books of account on the computer system. Therefore, the same could have been produced before the Assessing Officer during the course of assessment proceedings. There is no dispute that the office of the assessee-company was shifted from one place to other, but it is no .....

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in the bank account and from its perusal we find that certain credit entries are related to the transfer entries and cannot be part of cash deposits. We find force in the contention of the Revenue that whenever cash deposits are in the bank accounts, the onus is upon the assessee to explain the source and nature of deposit. During the course of hearing, the ld. counsel for the assessee has filed the statement of loan and advances and interest received during the impugned assessment year. But fro .....

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rd. Though it was contended on behalf of the assessee that it was on the verge of closing of its business and whatever amount was recovered from the debtors, it was deposited in the bank. But from a carful perusal of balance sheet, the facts are otherwise. 20. Having carefully examined the orders of the lower authorities on the impugned issue, we find that the Assessing Officer has made addition of the cash deposits in the bank accounts of the assessee having placed strong reliance upon the stat .....

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the bank. From the totality of the facts and circumstances of the case, we are of the view that this issue was not properly examined by the lower authorities. Before us the assessee has also furnished the details of various persons from who cash was received, but it requires a proper verification by the Assessing Officer. In the light of these facts, we are of the view that this issue requires a fresh adjudication by the Assessing Officer and we accordingly set aside the order of the ld. CIT(A) .....

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on two grounds - one is with regard to the deletion of addition of ₹ 5 lakhs made on account of disallowance of expenditure incurred on deposit of earnest money with the Bombay Stock Exchange. The other ground relates to the deletion of addition of ₹ 15.40 lakhs made by the Assessing Officer on account of its appearance in the balance sheet as advance as on 31.3.2006 and debited in the profit and loss account during the year. 22. With regard to first ground, the facts borne out from .....

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e-company failed to comply with the requirements, Bombay Stock Exchange forfeited the earnest money and communicated the same to the assessee-company in July, 2006. The assessee-company accordingly written off the said amount in its books of account as revenue expenditure which was disallowed by the Assessing Officer after treating it to be capital expenditure. 23. The assessee preferred an appeal before the ld. CIT(A) with the submission that the assessee had applied for the membership of Bomba .....

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ure. 24. Being convinced with the explanations of the assessee, the ld. CIT(A) has deleted the addition having observed that forfeiture of earnest money was business expenditure incurred on account of business expediency. The relevant observations of the ld. CIT(A) are extracted hereunder for the sake of reference:- Having gone through the facts of the issue, the observations of the AO & the submissions made by the Ld. A.R. in this regard, I am of the considered view that the said forfeiture .....

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trade in the BSE was not a new Lie or a separate business, but part of the same business. In this view of the matter, I am of the considered view that foregoing of "earnest money" by the assessee was a business expenditure incurred on account of "business expediency". Accordingly, I direct the A.O. to delete the impugned addition made. 25. Now the Revenue is in appeal before the Tribunal, but could not point out any defect in the order of the ld. CIT(A). He, however, placed .....

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In any case, the assessee has suffered a loss of ₹ 5 lakhs and the same should be allowed as revenue expenditure. Since we do not find any infirmity in the order of the ld. CIT(A), we confirm his order on this issue. 28. So far as the other ground relating to deletion of addition of ₹ 15.40 lakhs is concerned, we find that during the course of assessment proceedings, the Assessing Officer has noticed from the Schedule-6 forming part of the profit and loss account that the assessee h .....

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on 31.3.2006. However, under these two heads, the amount has been shown as Nil on 31.3.2007. The Assessing Officer observed that it appears that these two amounts of ₹ 7.70 lakhs each (Rs.15.40 lakhs) appearing in the balance sheet as on 31.3.2006 under the head loans and advances have been debited in the profit and loss account under the head rent . The assessee was required to furnish the details of expenses debited under the head rent and expenses thereof. In response it was stated tha .....

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ainst the assessee and thereafter the entire amount paid to Shri. L.C. Agarwal was transferred to rent account and is a liability to pay got crystalised in the event of final order having been delivered by the high judicial forums. The Assessing Officer was not convinced with the explanations of the assessee and he concluded that it is apparent that an amount of ₹ 15.40 lakhs which was appearing in the balance sheet as advance as on 31.3.2006 has been debited in the profit and loss account .....

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