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2015 (11) TMI 276 - ITAT DELHI

2015 (11) TMI 276 - ITAT DELHI - TMI - Undisputed forfeiture of the payment by a party related to the assessee - CIT(A) deleted the addition - Held that:- We are of the considered view that the learned First Appellate Authority has rightly deleted the addition of ₹ 5.85 croes made by the Assessing Officer because these expenses were incurred for the purpose of manufacturing of sugar in respective factories with a view to earn profit and, therefore, the assessee was entitled to deduction of .....

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eleted the addition - Held that:- First appellate Authority has given various details of various parties mentioned in the impugned order. The learned First Appellate Authority has also supported his view by various decisions rendered by Hon’ble High Courts which includes the jurisdictional High Court, which are mentioned in the impugned order. After going through the same, we are of the considered view that the learned First Appellate Authority has passed a well reasoned order on the deletion of .....

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dated 03.02.2011 passed by Civil Judge, Bangalore and copy of pending recovery suit for unpaid rent. After considering all these documentary evidences, the learned First Appellate Authority has deleted the addition of ₹ 20.47 lakhs. We find no infirmity in the deletion of disallowance of ₹ 20.47 lakhs. We uphold the impugned order on the issue involved in ground No. 3. No other point has been argued or raised before us by both the parties. - Decided against revenue. - ITA No. 4711/D .....

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s made by the AO by rejecting the contention of the AO that the undisputed forfeiture of the payment by a party related to the assessee was not genuine and at arms length. 2. The Ld. CIT(A) grossly erred in deleting the addition of ₹ 1.25 crores on account of advances received by the assessee ignoring that the assessee was unable to discharge the onus placed upon it to establish the genuineness of the transactions on the facts and circumstances of the case. 3. The Ld. CIT(A) grossly erred .....

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.09.2009. The case of the assessee was selected for scrutiny through CASS. The Assessing Officer issued notice u/s. 143(2) of the IT Act, 1961 (hereinafter called the Act ) on 22.08.2010. A detailed questionnaire along with notice u/s. 142(1) was also issued on 06.07.2011. In compliance to the same, the AR of the assessee appeared and filed necessary details, information/documents etc. as required. The books of accounts were produced and examined on test check basis. The assessee is engaged in t .....

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oduced in the assessment order. The Assessing Officer further asked the assessee about the relation of assessee firm with D.D. Goel who forfeited the amount of ₹ 5.85 crores. In response to the same, the assessee filed reply, which the assessing Officer has also reproduced in the assessment order. After considering the reply filed by the assessee along with documentary evidence, the Assessing Officer, completed the assessment by giving findings on the issue in dispute at pages No. 9 to 12. .....

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ssessee filed appeal before the learned first appellate authority, who vide impugned order dated 21.06.2012 allowed the appeal filed by the assessee and deleted the additions in dispute. Now, the Revenue is aggrieved against the impugned order dated 21.06.2012 passed by the CIT(A) and has filed the present appeal on the grounds mentioned above. 3. The learned DR relied upon the order passed by the Assessing Officer. On the contrary, the learned counsel for the assessee relied upon the order pass .....

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g Officer. After going through the impugned order, we find that the learned first appellate authority has decided the issue involved in ground No. 1, at pages 25 to 38 of the impugned order. For the sake of convenience, the same is reproduced as under : I have carefully considered the facts and circumstances of the case and submissions and details filed during the course of appeal proceedings. The only issue for consideration and adjudication IS genuineness of claim of loss on forfeiture of adva .....

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nt was not registered and as such the bonafide of the agreement is itself in doubt. Further, as per the Assessing Officer, the assessee s is main area of activity was in Bangalore and project at Sonipat, Haryana was not practical or feasible and in fact assessee itself has never been serious and no approval was obtained for undertaking the said project. The Assessing officer also made reference to report of the inspector as per which the farmers have not confirmed authenticity of agreements with .....

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on 15/06/2006. In terms of the said agreement, the assessee firm made the payment to the extent of ₹ 5.85 crores as advance and acquired right to develop the land for their prospective project at Sonipat. The appellant claimed to have entered into various other agreements with farmers for purchase of land at Sonipat, the copies of which have already been placed on record. It will be relevant to quote the development agreements entered into by the appellant with Sh. D.D. Goel and Sumit Goel .....

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; And Mjs DKG Company having its registered office at HS-38 Kailash Colony, New Delhi-I I 0048, through its Partner Sh. Amit Goel (hereinafter called the Second Party and also referred to as Developer which expression shall, unless it be repugnant to the subject or context thereof, include its assigns, legal representatives, successors and administrators etc.) of the Second Part; As per clause 9 of the said agreement payment was to be made @ of ₹ 60,00,000/ - per acre to the Associate by t .....

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ate shall have right to forfeit the deposit at his discretion. 15. That the Developer shall obtain necessary permission/license from the concerned authorities and start the development work with in 24 months from this agreement, incase developer defaults on any terms & conditions of this agreement, the Associate shall have right to forfeit the deposit at his discretion. Development Agreement with Sh. Sumit Goel This agreement is made on this 17th day of April, 2006 by and between: - Mr. Sumi .....

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so referred to as Developer which expression shall, unless it be repugnant to the subject or context thereof, include its assigns, legal representatives, successors and administrators etc.) of the Second Part; As per clause 9 of the said agreement payment was to be made @ of ₹ 60,00,000/- per acre to the Associate by the developer. 9. That the developer will give a deposit of ₹ 60,00,000/- (Rupees Sixty lakhs only) per acre to the Associate and further the sale proceeds will be share .....

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elopment work with in 24 months from this agreement, incase developer defaults on any terms & conditions of this agreement, the Associate shall have right to forfeit the deposit at his discretion. There is no dispute that the development agreement has been executed between related parties. However, whether the same is collusive or sham is to be considered in the light of the facts of the case and documents on record. There is no dispute that the partnership firm is engaged in the business of .....

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s no dispute that the said agreement is part of record and this fact is also corroborated from audited balance sheets, which have been called for and placed on record. It was further clarified that genuineness of the said agreement was examined during assessment year 2007-08 and there was no dispute or doubt in respect of said agreement or fact of payment of advance and business intention of the parties. In fact, it is only during assessment year 2009-10, when the forfeiture took place, the Asse .....

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erence to your letter dated 12.06.2008, explaining your intention to forfeit the advance amount in terms of development agreement dated 15.06.2006. In this regard, we may invite your kind attention to our earlier letter wherein the company had explained tits difficulties being faced fro start of the project and make the balance payment as per the agreement. As you are aware due to certain conditions we have not been able to take up the project till date, we kindly request you to extend the perio .....

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me about the progress of the project. I have to receive 20% of the sale proceeds also. Kindly note my money is blocked causing me heavy loss. As per clause 15 of said agreement since you have failed to fulfill your obligation, I hereby inform you that I have forfeited the advance amount of ₹ 5.85 crores paid by you to me. Kindly be informed that from now onwards the development agreement stands cancelled and you will have no claim against me and I shall be at liberty to deal with my land i .....

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ccess. There is no dispute that both the parties were capable of executing the agreement and the fact of agreement was acted upon and also supported from record. The issue of genuineness is to be considered only in the year the said agreement was executed. The appellant has able to demonstrate that the said agreement was duly executed during F.Y. 2006-07 and genuineness of the said agreement was also supported from audited accounts. If the said agreement was for the purpose of business interest .....

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siness interest, the assessee was not in a position to compete with them or to acquire the land at arbitrary price and as a prudent businessman and on account of business and commercial consideration, there was no possibility of any further progress in the light of requirement of minimum holding of land to the extent of 100 acres. However, the assessee was able to recover the advances paid to farmers as it was in their own interest as they were offered higher price by Jindal Group. However, Sh. .....

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after taking necessary legal advice. The objection of the Assessing Officer that agreement -was between related parties and as such same was sham or collusive could not be accepted as a general proposition under the provisions of the Income Tax Act. The firm and Sh. D.D. Goel, are independent assessee and capable of executing the said agreement on the basis of their respective business interest and once the legal rights of the parties to execute such agreement is not in dispute, no adverse infe .....

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recitals in those documents. The decision of Supreme Court in the case of McDowell & Co. is only in the context of colorable device in order to evade the tax liability by dubious methods. The decision of Supreme Court in the case of Durga Prasad More was in the context of diversion of income for tax advantage by using dubious documents. However, the Hon ble Supreme Court in the case of Union of India Vs. Azadi Bachaoo Andolan 132 Taxman 373 has itself disapproved the decision of Supreme Cou .....

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and not to question the same subsequently, merely on the ground that assessee has claimed some loss on the basis of said agreement .. There is no dispute that the said agreement was executed on 15/06/2006 and same was taken note of by the Assessing Officer during the course of assessment proceedings for assessment year 2007-08 and the agreement is also corroborated from audited accounts and as such it is too late in the day to consider the same agreement as sham or collusive. It may be appropria .....

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orfeiture of advance on the basis of business and commercial consideration and after proper legal advice, the Assessing Officer has to consider and allow the said loss, if the same is otherwise permissible under the provisions of Income Tax Act, 1961. In this connection, it is appropriate to make reference to latest decision of Delhi High Court in the case of CIT Vs. Micromatic Machine Tools (p.) Ltd. 192 Taxman 161 (DELHI) Section 37(1) of the Income-tax Act, 1961 - Business expenditure - Allow .....

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ition of management of assessee and take it upon himself to decide how much would be a reasonable expenditure for a particular business purpose - Held, yes - The observation of the Assessing Officer that the agreement to sale is not registered. In fact, the Assessing Officer himself has observed that there is no illegality involved for the same being not registered and genuineness of the agreement is to be considered on facts and business consideration. The appellant has been able to demonstrate .....

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er are not based on proper appreciation of facts or legal requirements for such approval. As per notification and guidelines issued by Financial Commissioner and Principle Secretary to Government of Haryana, Town and Country Planning Department Act, there was a minimum requirement of land holding of 100 acres and as such the assessee was not in a position to obtain the requisite approval. In the light of facts clarified by the appellant and other adverse factors and in the absence of acquisition .....

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, as Sh. D.D. Goel is an independent assessee and the matter has to be examined in the case of Sh. D.D. Goel. In any case, whether the forfeiture amount is to be considered as capital or revenue receipt in the case of Sh. 0.0. Goel, same could have no bearing to the case of the appellant as the appellant being in the business of real estate and loss being incidental to business activities, same is to be considered as of revenue nature and permissible deduction under the law. The observation of t .....

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tion of the Delhi High Court in the case of Dalmia Cement Ltd. 254 ITR 377 is relevant and appropriate. The observation of the Assessing Officer that there was no forfeiture clause in the case of other agreements with the farmers and as such various agreements were executed with different purposes and motivated by the claim of loss. I have considered the various agreements with the fanners and it is noted that in all such agreements, there was similar clause of forfeiture and as such the allegat .....

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rement and notification issued by Financial Commissioner and Principle Secretary to Government Haryana, Town and Country Planning Department Act. The observation about tax implication in the case of Sh. D.D. Goel is of no relevance for this appeal, as Sh. D.D. Goel is an independent assessee and the matter has to be examined in the case of Sh. D.D. Goel. In any case, whether the forfeiture amount is to be considered as capital or revenue receipt in the case of Sh. D.D. Goel, same could have no b .....

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business of development of real estate, it was open to the assessee to undertake the project at any place as may be decided by the appellant and it is not for the Assessing Officer to decide as to how the business is to be carried on. The observation of the Delhi High Court in the case of Dalmia Cement Ltd. 254 ITR 377 is relevant and appropriate. The observation of the Assessing Officer that there was no forfeiture clause in the case of other agreements with the farmers and as such various agr .....

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re on identical basis and for the purpose of execution of project at Sonipat. However, in the light of business interest, the issue of forfeiture with farmers was not enforced. Regarding the allegation that the inspector of the department personally visited the Village at Haryana and reported that farmers were not aware of the project of the appellant and they also expressed their ignorance for any such project or , any sale of land for the said project. However, whether Assessing Officer provid .....

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versely affect the claim of the appellant particularly when assessee was not confronted with the report of the inspector. Regarding observation that in respect of similar agreement with Sh. Sumit Goel, partner of the firm, there was no forfeiture and as. such the Assessing Officer doubted the business justification of forfeiture in the case of Sh. D.D. Goel. As per facts clarified, Sh. Sumit Goel is partner of the firm and as such there could be no forfeiture between firm and partners as partner .....

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& Co., I have already dealt with the nature of the business activities and genuineness of the agreement in the context of principle laid down by the Supreme Court and as such these general observation have no adverse implication or affect the claim of the appellant, if otherwise permissible under the law. In fact, the assessee has been able to establish that a genuine agreement was executed with Sh. 0.0. Goel based on business interest of both the parties and same have been acted upon by the .....

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he loss is incidental to business and same has to be allowed as revenue loss. The above said position. is also supported from various judicial authorities referred to hereunder: Havells India Ltd. vs. ACIT 13 Taxmann.com 64 (Delhi) Section 37(1) of the Income-tax Act, 1961 - Business expenditure - Allow ability of - Assessment year 2005-06 - Assessee-company was engaged in business of manufacture of electrical products - It had its head office at Delhi and manufacturing units at various places i .....

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was complete interlacing and intermixing of funds of assessee in all its units, lower authorities were wrong in treating expenditure in question as capital expenditure - Held, yes. CIT Vs. Ghanashyam Steel Work Ltd. 195 TAXMAN 180 (GUJ.) Section 37(1), read with section 36(I)(iii), of the Income-tax Act, 1961 - Business expenditure - Allow ability of - Assessment years 1996-97 to 1998-99 - Assessee was engaged in business of manufacture of chemical processing equipment - During relevant assessm .....

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xpenses - Both, Tribunal as well as Commissioner (Appeals), had recorded concurrent findings of fact that so called new unit was merely an expansion of existing business of assessee and was not setting up of a new business and, as such, expenses incurred in this regard were allowable as revenue expenses - Further, considering the fact that Assessing Officer had not considered claims of each of items of expenditure incurred by assessee from angle as to whether same were in nature of revenue or ca .....

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93 - Assessee-company had three sugar manufacturing units - During relevant assessment year, it set up two new sugar factories and claimed deduction of expenses incurred by way of salary, wages, bonus, workmen s welfare expenses, manufacturing expenses, rent for office building, etc., for purpose of running of said two units - Whether since aforesaid expenses were incurred for purpose of manufacture of sugar in respective factories with a view to earn profit assessee was entitled to deduction of .....

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ned first appellate authority has adjudicated this issue at page 38 to 42 of the impugned order. For the sake of convenience that is reproduced as under : I have gone through the assessment order and written submissions of the appellant. The Assessing Officer made an addition of ₹ 1,25,00,000/- as income from undisclosed sources in respect of advance received from various parties against future projects. The particulars of advances have been given in the assessment order and extracted here .....

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d hereunder: There is no dispute that payments from all the parties were received through account payee cheques and confirmation of these parties alongwith permanent account number were furnished. In fact, these are all trade advances in connection with business activities and these advances were received in connection with various ongoing and future projects of the appellant firm. The particulars in respect of these parties were furnished during assessment proceedings and are extracted hereunde .....

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ement from which the fact of such advances is fully orroborated 3. Mukesh Kumar i. Copy of account alongwith confirmation and PAN No. ii. Copy of acknowledgement receipt in respect of income tax return for assessment Year 2008-09. 4. Payal Goel i. Copy of account alongwith confirmation and PAN No. ii. Copy of acknowledgement receipt in respect of income tax return for assessment Year 2009-10. iii. Copy of bank statement from which the fact of such advances is fully corroborated 5. Saraswatl Trad .....

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submitted that the Assessing Officer has not disputed identity of the parties and genuineness of other supporting documents. Further, the Assessing Officer himself observed that- information has been passed on to the concerned Assessing officer for appropriate action in the case of concerned parties in the context of these advances. Subsequently, these advances have been repaid through account payee cheques as there was no possibility of development of mutually acceptable projects. Further, the .....

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ommissioner of Income Tax, Orissa Vs. Orissa Corporation Pvt.Ltd. Page 159, ITR 78 Held, that in this case the respondent had given the names and addresses of the alleged creditors. It was in the knowledge of the Revenue that the said creditors were income-tax assessee. Their index numbers were in the file of the Revenue. The revenue, apart from issuing notices under section 131 at the instance of the respondent, did not pursue the matter further. The Revenue did not examine the source of income .....

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n could be arrived at, no question of law as such arose. The High Court was right in refusing to state a case. Further, the issue of source of source is not relevant particularly when all these parties are regular income tax assessee and Assessing Officer himself has made reference to concerned Assessing Officer for necessary action in the matter. In this connection, reference may be made to decision of Delhi High Court in the case of CIT Vs. Diamond Products Ltd., 177 Taxman 331. The above said .....

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shed. In the instant case, it had been done. Therefore, it was not open to the Assessing Officer, to make the addition of the amount in question after the examination of the source of the source. In any case, the Assessing Officer has not brought on record any evidence that these advances represent undisclosed income of the assessee and as such there could be no ground for any adverse inference. The legal position to this effect is supported from decision of Delhi High Court in the case of CIT V .....

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uineness of the transactions but dispute is only on the ground of capacity and source of such advance. Further, these advances have subsequently been refunded through account paid cheques in the absence of development of any mutually acceptable project. I have carefully considered the various case laws referred to by the appellant in their written submission and I am in agreement with the principles laid down in those judgments. The principle laid by Supreme Court in the case of Orissa Corporati .....

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on, the impugned addition is not sustainable and same is hereby deleted. Appeal on this ground is allowed. 6. Similarly, after going through the impugned order, we find that the learned First Appellate Authority has dealt with the third issue regarding deletion of disallowance of ₹ 20.47 lakhs on account of rent receivable from let out property at pages 46 to 49 of the impugned order. For the sake of convenience, that is reproduced as under : I have gone through the assessment order and wr .....

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s been considered that assessee has adjusted the six months rent with security deposit. Therefore, six month rent i.e. ₹ 4,87,500 x 6 = ₹ 29,25,000/- is considered at rental income of assessee. However, 30% standard deduction vi] s. 24(a) of Income Tax Act, 1961 is provided to the assessee i.e. of ₹ 8,77,500/-. After providing the deduction balance of the amount i.e. ₹ 20,47,500/- is added to the returned income of the assessee as income from house property . The appellan .....

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civil suit, the Hon ble civil Judge vide order dt. 03/02/2011 directed M/ s. GKB Optolab Ltd. to vacate the property within two months and as per the direction of the court, property has been vacated. However, the issue of payment of rent is still subject matter of dispute. All the relevant facts were duly clarified to the Assessing Officer vide our letter dt. 10.10.11 and for your reference following documents are enclosed. i. Copy of letter dt. 10/10/2011 ii. Copy of rent agreement. iii. Copy .....

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ugned addition in respect of unpaid rent on the basis of security deposit with the assessee. The action of the Assessing Officer is uncalled for in the context of fact that there was no receipt of rent for the period of 6 months and legal dispute was before the court of civil judge and as such the assessee could not have adjusted rent against the security deposit in the absence of proper settlement of dispute between the parties or direction of the court. In fact, regarding recovery of rent, the .....

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icial authorities and as such there could be no addition on hypothetical and notional basis. The security deposit was refundable and in the absence of specific direction of court or mutual settlement between parties, it was not possible to adjust the rent against security deposit, particularly when the matter was in dispute and subjudice. I have carefully considered the relevant facts and contentions of the parties. There is no dispute that the appellant has not received rent for a period of 6 m .....

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at issue of tenancy and rent was in dispute, the Assessing Officer cannot make such adjustments on hypothetical basis. In View of the above discussion, there is no justification for the Assessing Officer to consider addition of rent on the basis of security deposit unless there is direction of the court to this effect or agreement between the parties. It is not for the Assessing Officer to lay down conditions and guidelines regarding adjustment in the absence of any factual or legal basis. Non r .....

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iven by the learned First Appellate Authority on the issue involved in appeal filed by the department, we are of the considered view that the learned First Appellate Authority has rightly deleted the addition of ₹ 5.85 croes made by the Assessing Officer because these expenses were incurred for the purpose of manufacturing of sugar in respective factories with a view to earn profit and, therefore, the assessee was entitled to deduction of the said expenses as Revenue Expenditure. After goi .....

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der on this ground. 8. As regards to the deletion of addition of ₹ 1.25 crores on account of advances received by the assessee, after going through the impugned order, as well as the Assessing Officer, we are of the view that the learned First Appellate Authority has elaborately discussed the issue at pages 38 to 42 of the impugned order. The learned First appellate Authority has given various details of various parties mentioned in the impugned order. The learned First Appellate Authority .....

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