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2015 (12) TMI 771

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..... eedings and subsequent addition through its return income for AY 2003-04 was unjustified. After the assessee's return was processed under Section 143 (1), the Assessing Officer issued a notice under Section 147 and 148 stating that income has escaped assessment to the tune of Rs. 77,29,146/-. The AO was of the opinion that in terms of Section 43B, four enumerated amounts had to be disallowed inas .....

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..... profit and loss a/c, the assessee has shown receipt as parking contractor at Rs. 92,35,983/- and against this has shown expenditure as Licence Fee of Rs. 79,34,016/-. This expenditure has been allowed while processing the assessee's return on 29.3.2004, as claimed. A perusal of the Balance Sheet filed by the assessee with the return of income, reveals that under the head current liabilities th .....

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..... tent of Rs. 77,29,146/- chargeable to tax, has escaped assessment in terms of section 147 of the Income Tax Act, 1961." The Tribunal was of the opinion that the facts and figures of liabilities had already been declared and disclosed by the assessee in its balance sheet for the concerned assessment year and that no material or information has come to the possession of the AO justifying the reope .....

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