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2016 (7) TMI 377 - ITAT AHMEDABAD

2016 (7) TMI 377 - ITAT AHMEDABAD - TMI - Revision u/s 263 - non eligible for grant of deduction under section 80IB(10)(c) - Held that:- AO, though, not made elaborate discussion with regard to the issue associated with section 80IB(10) claim, but has gone through all the details. It is discernible from the queries raised by him and the explanation given by the assessee in various replies. It is also pertinent to observe that in the Asstt.Year 2009-10, under similar situation in the same project .....

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der of the ld.Pr.Commissioner of Income-Tax-2, Ahmedabad dated 13.2.2015 passed under section 263 of the Income Tax Act, 1961 in the Asstt.Year 2010-11. 2. Though the assessee has taken five grounds of appeal, but its grievance revolves around a single issue viz. that the ld.CIT has erred in taking action under section 263 of the Income Tax Act and cancelling the assessment order dated 24.12.2012 passed under section 143(3) of the Act, directing the ld.AO to make a fresh assessment order. 3. Bri .....

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the accounts, it revealed to the AO that the assessee had claimed deduction of ₹ 5,25,20,351/- under section 80IB of the Income Tax Act. According to the AO, vide order sheet dated 31.10.2012 the assessee was asked to submit complete details with respect to its claim. The assessee has submitted details called for vide his reply dated 3.12.2012, 4.12.2012 and 10.12.2012. The ld.AO has allowed the claim of the assessee by observing that the assessee has claimed parity with the facts of Radh .....

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perusal of the record, the ld.Commissioner harboured a belief that the assessment order dated 24.12.2012 passed by the AO is erroneous insofar as it is prejudicial to the interest of Revenue. He issued a show cause notice dated 20.12.2014 under section 263 of the Income tax Act. Copy of the show cause notice has been placed on page no.67 to 69 of the paper book. The relevant part of the show cause notice has been reproduced by the ld.Commissioner in the impugned order, which reads as under: 1. T .....

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put up, belonged to Dharti Vikas Co op Housing Soc Ltd. and it had applied for development of housing scheme on 10.04.2006 and got the permission in its name on 30.03.2007 from ADDA. The assessee ie. Hindustan Home Fin.Ltd., entered into a Development agreement with Hindustan Home Fin Ltd. on 12.04.2007 only. Infact, the assessee Hindustan Home Finance Ltd. has not only taken the development rights but has also tried to transfer the approval of the plan obtained by Dharti from cm appropriate aut .....

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Hon. High Court in the case of Radhe Developers. The Department, however has preferred second appeal before the Hon.ITAT in Appeal No. 1997/AHD/2012 dtd. 05.11,2012 which is pending for the decision. Therefore, the AO has allowed assessee's claim of deduction u/s 80IB of the Act, without application of correct provisions of law and has taken inconsistent decision in light of the Department's stand on this issue in assessee's own case for earlier A.Y. 2. Notwithstanding the above, on .....

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tificate, the measurement of closing W.I.P. is reported at 22125 sq.mtrs. having value of ₹ 23,34,70,0187- and per sq.mtr. value once again works out to ₹ 10,552/-. Further, assessee has shown decrease in stock of W.I.P. for the year under consideration at ₹ 15,74,70885/- which if divided by the area construction sold by assessee during the year under consideration at 16969 sq.mtrs., the p.sq.mtr. value works out to ₹ 9,280/-. Infact, assessee had incurred further expense .....

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rly, assessee has shown the amount of AEC ADDA charges received from members ₹ 72,90,525/- and student fees of ₹ 3,21.500/- as an income in its P & L A/c. The sum so received cannot be treated as an income in the hands of the assessee company as the same is to be paid to AEC & AUDA. On perusal of assessee's P &L A/c, it is seen that no corresponding expenses have been debited by the assessee. The income from student fees is not an eligible activity for claim of deduct .....

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ted to modify the same on the issues mentioned above. 5. In response to the show cause notice, the assessee has filed a detailed reply which has been reproduced by the ld.Commissioner from page nos.4 to 31 of the impugned order. After going through the reply of the assessee, the ld.Commissioner has set aside the impugned order. He directed the AO to pass a fresh assessment order. 6. With the assistance of the ld. representatives, we have gone through the record carefully. Section 263 has a direc .....

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order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment. [Explanation.- For the removal of doubts, it is hereby declared that, for the purposes of this sub-section,- (a) an order passed on or before or after the 1st day of June, 1988 by the Assessing Officer shall include- (i) an order of assessment made by the Assistant Commissioner or Deputy Commissioner or the Income- tax O .....

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d all records relating to any proceeding under this Act available at the time of examination by the Commissioner; (c) where any order referred to in this sub-section and passed by the Assessing Officer had been the subject matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as had not been considered and decided in such appeal. (2) No order shall .....

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tion.- In computing the period of limitation for the purposes of sub-section (2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded. 7. A bare perusal of the sub section-1 would reveal that powers of revision granted by section 263 to the learned Commissioner have four compartments. In the first place, the learned Co .....

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Assessing Officer, he formed an opinion that such an order is erroneous in so far as it is prejudicial to the interests of the Revenue. By this stage the learned Commissioner was not required the assistance of the assessee. Thereafter the third stage would come. The learned Commissioner would issue a show cause notice pointing out the reasons for the formation of his belief that action u/s 263 is required on a particular order of the Assessing Officer. After this stage the opportunity to the as .....

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it pertinent to take note of the fundamental tests propounded in various judgments relevant for judging the action of the CIT taken u/s 263. The ITAT in the case of Mrs. Khatiza S. Oomerbhoy Vs. ITO, Mumbai, 101 TTJ 1095, analyzed in detail various authoritative pronouncements including the decision of Hon ble Supreme Court in the case of Malabar Industries 243 ITR 83 and has propounded the following broader principle to judge the action of CIT taken under section 263. (i) The CIT must record s .....

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ind, such order will fall under the category of erroneous order. (v) Every loss of revenue cannot be treated as prejudicial to the interests of the Revenue and if the AO has adopted one of the courses permissible under law or where two views are possible and the AO has taken one view with which the CIT does not agree. If cannot be treated as an erroneous order, unless the view taken by the AO is unsustainable under law (vi) If while making the assessment, the AO examines the accounts, makes enqu .....

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) The CIT, before exercising his jurisdiction under s. 263 must have material on record to arrive at a satisfaction. (ix) If the AO has made enquiries during the course of assessment proceedings on the relevant issues and the assessee has given detailed explanation by a letter in writing and the AO allows the claim on being satisfied with the explanation of the assessee, the decision of the AO cannot be held to be erroneous simply because in his order he does not make an elaborate discussion in .....

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s. The following observations of the Hon'ble Delhi High Court are worth to note: 12. We have considered the rival submissions of the counsel on the other side and have gone through the records. The first issue that arises for our consideration is about the exercise of power by the Commissioner of Income-tax under section 263 of the Income-tax Act. As noted above, the submission of learned counsel for the revenue was that while passing the assessment order, the Assessing Officer did not consi .....

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to give detailed reason in respect of each and every item of deduction, etc. Therefore, one has to see from the record as to whether there was application of mind before allowing the expenditure in question as revenue expenditure. Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between lack of inquiry and inadequate inquiry . If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass ord .....

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to make further inquiries before cancelling the assessment order of the Income-tax Officer. The Commissioner can regard the order as erroneous on the ground that in the circumstances of the case the Income-tax Officer should have made further inquiries before accepting the statements made by the assessee in his return. The reason is obvious. The position and function of the Income-tax Officer is very diffident from that of a civil court. The statement made in a pleading proved by the minimum am .....

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ch as to provoke an inquiry… It is because it is incumbent on the Income-tax Officer to further investigate the facts stated in the return when circumstances would made such an inquiry prudent that the word erroneous in section 263 includes the failure to make such an enquiry. The order becomes erroneous because such an inquiry has not been made and not because there is anything wrong with the order if all the facts stated therein are assumed to be correct. 10. In the light of the above, .....

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oop. Housing Society on 12.4.2007. Prior to the entrance of agreement, there was an oral consent between both the parties. The ld.Commissioner has rejected this plea of the assessee by observing that the assessee has alleged purchased of substantial right including development rights for ₹ 1,19,50,197/-. The AO has not verified what is the treatment given by the Dharti Vikas Coop. Housing Society to the receipt of ₹ 1,19,50,197/-. According to the ld.Commissioner a notice under secti .....

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details exhibiting comparison between the facts of the assessee vis-à-vis that of Radhe Developers before the Hon ble High Court. The assessee has submitted reply on 20.12.2012. Copy of this reply has been placed on page no.51 of the paper book. In this reply, the assessee has disclosed the following facts:- Sr. No. CASE BEFORE HIGH COURT ASSESSEE COMPANY s CASE 1 The assessee company had claimed deduction under Section 80IB(10) of the Income Tax Act, 1961 on the premise that such income .....

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irs of deceased Ambalal Motibhai Patel as party of the Second Part. In the said development agreement dated 18.5.2000, the assessee company was referred as a party of the Third Part. (as per para 3 of order) The assessee company has also entered in to two development agreements with society in para 1 herein above. 3 Relevant Terms and conditions of development agreement (Para 25 of order) (i) "3. The party of the third Part is connected with the construction of business since many years and .....

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er wants to do a project/scheme of constructing residential houses having area less than 1500 sq.ft. For the middle class society In the second para of page no 4 it has been mentioned that society has entered into development agreement with assessee company for which oral agreement is also executed. (iii) 5. The Party of the First and The Party of the Third Part have executed one Agreement of Sale on 18-05-2000 accordingly on that basis the rights of agreement of Sale dated 7-9-91 at the rate of .....

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es having area less than 1500 sq.ft. for the middle class society and also have no finance to invest as per the size of scheme and to register the members for that required alertness and skill being absent they themselves are not in a position to place a project or scheme on the land mentioned in schedule in such circumstances to The Party of the Third part over and above the right to purchase the rights of Agreement of Sale on dt.18-05-2000 they have also decided to give all rights along with c .....

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o sufficient funds for development and construction hence developer has to invest at their own risks in scheme. As per clause 1 of the agreement, for the purpose of development of project, the direct possession of the land as per law has been given to assessee company along with all power and rights. (v) 9. The said Developer cum Building Contractor by doing discussions with The Party of the First and Second Part confirming party, to bring the scheme in reality of constructing houses and get thr .....

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e company developer has to construct building work on land as per plan and specification prepared by architect. The assessee company developer at its own responsibilities can divide land including internal roads and margins and construct common plot from buyers of units as per requirement and demand of scheme. (vi) Other important conditions of clause 11 of agreement as discussed in Radhe case. (1) To appoint Architect Engineers, Legal Advisor and such professionals whose services for completing .....

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oper is aware about services provided by such persons. 3)The said Developer cum Building Contractor is authorized to admit the persons who are willing to join in the scheme to get the houses of fixed area and in this manner to admit the respective member in the scheme or at the time of admission of such member as per the scheme the fixed amount of contribution of construction and other amounts and incidental expenses that the admitting members shall have to pay as admission fees the receipt of d .....

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s and circumstances. Further, developer is entitled to fix the mode of payment and time etc. The developer is entitled to receive money from buyers as per their financial requirements hence value of units to be allotted to buyers may be different considering mode of payment, time of payment, area of units, location & situation of unit etc. Further, when developer has decided different rates, society or other member will not object against same. At clause no 24, it has been agreed that assess .....

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an mortgage the land and construction on such land for obtaining finance required for the project. 10) To complete this scheme in the prescribed time period and for the purpose of admitting the members in the scheme, to give advertisement of the total or partial scheme in local news paper or to print out its booklet, to place sign board, neon board on site the rights and authorities are hereby given to the Developer cum Building Contractor. As per clause 15 of the development agreement, it has b .....

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and also out of this land deducting the constructed land and deducting the land of margin and passage whatever excess land that shall remain then Developer cum Building Contractor shall have right to allot that land. As per clause 22 of the agreement, it has been agreed that assessee company developer is entitled to fix sale price of housing unit to members and proposed unit holders to scheme in lieu of their allotment of unit. Further as per clause 27 of the agreement, it has been agreed that .....

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l houses and incidental work there to and therefore the said Developer cum Building Contractor has to complete this scheme as per his own talents, whatever he deems proper as per his discretion and decisions. The accounts right from the implementation of this Agreement up to the completion of the project, Developer cum Building Contractor has to maintain in his office in his books of accounts and it is the liability and responsibility of Developer At clause 2 of the development agreement it has .....

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internal roads and margins and construct common plot from buyers of units as per requirement and demand of scheme. Further at clause 3 of the agreement, it has been agreed that for development and construction of housing project, assessee company will prepare construction plan, elevation, section, drawings etc and whatever material and specification will be finalized after discussion with architect and all the permission required from necessary authorities will be taken by it only. (14) The land .....

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of project. Further as per clause 27 of the agreement, it has been agreed that till the date when entire construction on said land is completed and assessee company receives the money from different members, the possession of impugned land construction thereon will be with assessee company. At clause no 28, it has been stated that till the completion and transfer of construction over the land, ownership of such construction will rest upon developer. Further, till amount is not received towards .....

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ng place etc. (24) The amount of total collection received from person becoming member in this scheme out of that the amount shall become payable to The Party of the First that is paid to Second Part by them and to The Party of the First shall be entitled to receive consideration as per the Agreement dt.18-5-2000 and after deducting that remaining all amount shall be received by The Party of Third Part as his remuneration." As per clause 26 of the development agreement, developer is entitle .....

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he ld.Commssioner is that the AO has not issued notice to Dharti Vikas Coop. Housing Society in order to inquire of the treatment that concern has made to the receipt of ₹ 1,19,50,197/- received from the assessee. How this question is relevant in the assessment of the assessee. The stand of the assessee is that it has paid substantial amount of ₹ 1.19 crores for purchase of development rights and of other rights. Whatever may be treatment given by Dharti Vikas Coop. Housing Society t .....

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led appeal before the Tribunal vide ITA No.1197/Ahd/2012. The Tribunal has dismissed the appeal of the Revenue vide order dated 2.3.2016. According to the ld. counsel for the assessee, in a way, the issue in dispute is covered in favour of the assessee by the order of the Tribunal. He emphasised that for sake of argument, even if on the ground of non-consideration of any particular issue at the time of assessment proceedings, this order under section 263 is being upheld, then ultimately, followi .....

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e, has observed that the order of the CIT is under challenge before the Tribunal by the Revenue. 14. On consideration of all these aspects, we find that the issue in dispute is squarely covered in favour of the assessee by the order of the ITAT. The finding of the Tribunal in the Asstt.Year 2009-10 reads as under: 4. Aggrieved by the order of A.O., assessee carried the matter before the ld. CIT(A) who deleted the addition by holding as under: "3.7 In the present case, appellant has fulfille .....

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As per the development agreements entered with Society, Society is entitled to value of land as stated herein above and all the profit/gains and losses, if any, arising on the completion of the project has to be borne by appellant. This fact proves beyond doubt that Assessee has become de-facto owner of the land and took the full risk of executing the housing project and thereby making profit/loss, as the case may be. Further, as per various clauses of development agreement entered with the Soc .....

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Act. These facts of appellant are similar to the fact of the case before the Hon'ble Gujarat High Court in case of Radhe Developers referred herein above wherein it has been held that when developer has obtained the possession of the land, it would be the owner of the land for the purpose of claiming deduction under Section 80IB(10) of the Act even though title of land has not passed to appellant. Further, the Hon'ble Court in various paras of the Order has given categorical finding tha .....

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her, the plans prepared for the purpose of proposed construction of buildings were prepared by appellant- developer after appointing architect and the entire revised plan, if any required, and building use permission and all other approval required for development of the project was to be obtained by appellant-developer only. (iii) Appellant-developer was entitled to fix sale price of housing unit to proposed buyers in lieu of their allotment and even it was entitled to fix the mode of payment, .....

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margin land was with appellant company. It has been agreed between both the parties that till the realization of sale consideration from proposed buyers, possession and contractual lien on such unsold area will be with appellant company. (v) Appellant was entitled to give advertisements in any form for the sale of housing units at its own cost. (vi) Appellant-developer was entitled to mortgage the land and construction on impugned land on which housing project has been developed for obtaining f .....

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llant has shown closing work-in progress and closing un- sold units in its Profit & Loss Account, which also proves that ownership of unsold unit is of appellant and not of Society. Further, appellant has received entire sale consideration from the buyers of the units as per rates decided by it only. At the time of execution, of sale deed, appellant is one of the parties to such agreement which also proves appellant is one of the parties for transfer of property to buyer of the units. Appell .....

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land has not passed to Assessee and development permission may be obtained in the ITA No.1997/Ahd/12 A.Y. 2009-10 (ITO vs. Hindustan Homefina Ltd.) 5 name of original land owner. In short, appellant has taken full risk of executing the housing project and was entitled to all the profit and gains including losses, if any, arising from sale of housing units, which proves beyond doubt that appellant is developer-cum- builder and not a contractor, as observed by the Assessing Officer. Appellant has .....

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pril, 2001 has no bearing on appellant. The facts of appellant's case are identical with the facts of case before the Hon'ble Gujarat High Court in case of Radhe Developers and respectfully following the decision of jurisdictional High Court and on facts and circumstances of appellant's case, disallowance of deduction under Section 80IB(10)made by Assessing Officer is deleted. The related ground of appeal is allowed." 5. Aggrieved by the order of ld. CIT(A), Revenue is now in ap .....

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he owner of the land and according to him, the assessee was merely a contractor. We find that ld. CIT(A) while deciding the issue in favour of assessee and after perusing the development agreement has given a finding that assessee had acquired land from the society at fixed cost and society was not entitled to any further benefits arising from development of the project, all the development and construction of the project was carried out be assessee at its own risk and the assessee had borne all .....

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e case of Radhe Developers 341 ITR 403, which was decided by the Hon'ble Gujarat High Court in assessee's favour. Before us, Revenue has not brought on record any material to controvert the findings of ld. CIT(A). In view of the aforesaid facts, we find no reason to interfere with the order of ld. CIT(A) and thus, the ground of Revenue is dismissed. 15. Next aspect considered by the ld.CIT in his order under section 263 is that flat sold by the assessee were having area of more than 1500 .....

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has not made reference to any document in the impugned order. We have considered this aspect also, and we find that the AO has inquired this aspect, more so, same plan was available in the Asstt.Year 2009-10, where the assessee was found to be eligible. This, reason is also not sufficient reason to uphold the order of the CIT under section 263 of the Income Tax Act. 16. Next reason assigned by the ld.CIT is that the assessee has inflated the value of stock of work-in-progress in the opening sto .....

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this WIP would become opening WIP for the Asstt.Year 2010-11. If the assessee inflated opening WIP then the profit for the current year would be reduced. The assessee also contended that it has no other project during the year. Its project is eligible for deduction under section 80IB(10) of the Act. The rate of deduction is also same in all these years. It will not affect the taxability in any of these years. The ld.CIT reproduced the objections and explanation of the assessee, but did not conc .....

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s considered this aspect. The Hon ble High Court has held that while exercising jurisdiction under section 263 of the Income Tax Act, the ld.Commissioner has to record a finding as to how the assessment is erroneous. In the absence of such finding, exercise of jurisdiction under this section is not sustainable. According to the Hon ble Delhi High Court, CIT cannot direct re-consideration of this type of ground. The ld.CIT has to record a finding as to how order is erroneous, and this finding can .....

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ucted inquiry, has gone through actual details. Now, CIT picked up an issue that supporting details were not called for. The Hon ble Delhi High Court has held that such supporting details ought to be called for by the CIT and ought to have demonstrated the error, only thereafter, this type of reason can be relevant corroborating reasons for setting aside the assessment order. 17. The next reasons assigned by the ld.CIT are that the assessee has collected AEC/AUDA charges from the customers and s .....

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