TMI Blog2012 (1) TMI 327X X X X Extracts X X X X X X X X Extracts X X X X ..... the learned CIT(A) further erred in not annulling order of the learned AO which was framed by him beyond time provided in section 153(2) of the IT Act 1961 which was extended by learned AO by appointing Special Auditors u/s 142(2A) and extending their time again and again thus taking benefit of proviso to sec.153(4). 2.2 Ground of Appeal 1 by assessee for Assessment year 2005-06 to 2008-09 reads as under:- That under the facts and circumstances of the case the learned CIT(A) erred in not annulling the order of the learned AO which was based on report of the learned Special Auditors who were appointed for the assignments beyond the provisions of sec.142(2A) of the Income Tax Act, 1961. Reliance in this regard is made on decision of Hon ble Jurisdictional High Court in CIT vs. Bajrang Textiles 205 CTR 287 (Raj.). 2.3 The facts in this case are similar to the facts in the case of Shri Ritesh Somani. While deciding the appeal in the case of Shri Ritesh Somani in ITA No. 592 to 597 JP/2011 and 618 to 623/JP /2011 vide order dated 30-12-2011, we have held that reference for special audit is in accordance with the provisions of law. Following that order, we dismiss the above ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a Vs. ITO (2009) XLI Taxworld 59 (Jd.). As after computation of income u/s 44AE income from gitti business is 5.14%, which being reasonable it should not be interfered. 3.5 In further alternate, the assessee submitted that income from vehicles subject to depreciation and interest was 14.81% whereas in case of Orient Mail Speed Transport Service Vs.ITO (2008) XL TW 138(JP) Hon ble ITAT Jaipur Bench approved NP rate of 6.76%. . The assessee therefore requested that profit being fairly well addition be deleted. 3.6 The ld CIT(A) considered submissions but finally applied submission made by assessee in para 3.5 above partly. As the profit in relation to income from gitti supply was worked out in this process at 5.14%, he considered it low, applied NP rate of 10% and made addition of ₹ 232318/-. Relevant part of ld. CIT(A) s order is reproduced as under:- As mentioned by appellant, he has declared net profit of ₹ 289773/- in his Profit Loss Account which includes income from Gitti Supply as well as transportation business. In the absence of correct and complete books of accounts, it will be proper to estimate income from transportation business as per the provisi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Hon ble CIT(A) did not considered followings:- (i) That our vehicles are being used in our gitti supply business also whereas income from plying of vehicles considered separately inconsonance to provision of sec.44AE. (ii) That assessee being a supplier to Railways where there is cut throat competition, margin of profit is comparatively less. We therefore request your honour that rate applied by Hon ble CIT(A) is too high and our disclosed Profit rate @ 5.14 being very reasonable the same be accepted in view of decisions of this Hon ble Bench. In alternate we request that a reasonable rate be applied. 3.8 We have heard both the parties. The chart of receipt other details as filed by the ld. AR is as under:- Particulars A.Y.2004-05 A.Y. 2005-06 A.Y.2006-07 A.Y.2007-08 A.Y.2008-09 DISCLOSED INCOME 1. net profit A 289773 272298 259479 490986 484386 Truck 224651 303779 136699 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 535311 629664 427791 838485 1254492 5(i)Transportation Receipts 3613257 2796992 2201825 5172417 4915737 (ii) Income subject to Depreciation and intt Bank 536311 629664 427791 838485 1254493 (iii) N.P.% vis a vis transportation receipt 14.81% 22.51% 19.43% 16.21% 25.52% 6.Income From grit supply business (i) Sales 4784456 5471468 88189 3605514 4640597 (ii) income subject to depreciation on car etc 246128 180182 120056 281998 259091 (iii) N.P. % vis a vis sales (Subject to depreciation ) 5.14% 3.29% 13.63% 7.82% 5.58% ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 07 2,47,851 8.04% 2007-08 4,86,507 5.54% 2008-09 4,36,144 4.56% 3.10 The depreciation in assessment year 2006-07 is only ₹ 2.40 lacs as against ₹ 4.90 lacs of earlier year. In the assessment year 2007-08 and 2008-09, there are lime stone sales in addition to grit sales. Such lime stones were not existing in earlier years. In the assessment year 2006-07, the turnover is only around ₹ 30.00 lacs as against around ₹ 85.00 to 90.00 lacs in other years. Therefore, the case for the assessment year 2006-07 is not at all comparable. Neither the AO nor the ld. CIT(A) has referred to any comparable cases. It is an admitted position that net profit rate will depend upon proportion of transportation receipts and grit sales as compared to the total turnover . Considering the nature of expenses debited in trading and profit and loss account and the fact that major expenses are in respect of purchases. We therefore, feel that it will be fair and reasonable to apply net profit rate of 6% for the assessment year 2004-05 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ok was not available therefore I could not get it verified, however, I submitted that of these purchases, purchases to the extent of ₹ 1439800/- were from my son's firm M/s Swastik Stone Crusher which is being reported by my auditors also in their report inform 3 CD in para 18 and therefore the same be reduced from it. Besides I also stated that payment of purchase of ₹ 134940/- to Choudhary Crushers is verifiable from my accounts and the said firm has also confirmed it which is evident from para 2 of the learned AO's letter also therefore the same also be reduced. Besides my request was that purchase of ₹ 948676/- is overlapping which is evident from page 48 49 of Annexure 20 also. I had therefore requested that purchases of ₹ 4369704/- be reduced by Rs.l439800/-(purchases from my son's firm Swastik Stone Crushers as per report of auditors inform 3CD), ₹ 134940/- (as per para 2 of letter of learned AO) and ₹ 9486761- (page 48 49 of 'Annexure 20) which shall bring nett undisclosed purchases, as per impounded records, to ₹ 1846288/-. However the learned AO not only did not grant me deduction for it but after making hypoth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deptt. because this is purchases which is either duly incorporated or it is already appearing in accounts which is verifiable from the records lying with learned AO. The assessee also submit that deptt. has not agitated it in remand letter also. In view of this fact it is simply a case of application of profit rate on balance purchases of ₹ 1846288/- and therefore deptts appeal deserve to be dismissed. There are plethora of judgments wherein this Hon ble Bench has held that in case of undisclosed sales disclosed profit rate should be applied. In view of this factual and legal position, the assessee requested to direct AO to apply the disclosed rate on unverifiable purchase of ₹ 1846288/-. 4.7 On the other hand, the ld. DR supported the orders of the AO. 4.8 We have heard both the parties. In the cases of Ritesh Somani and Smt. Meena Somani, we have held that profit is to be added to the income in respect of undisclosed sales. Following our findings in the case of Shri Ritesh Somani and Smt. Meena Somani, we hold that profit is to be applied on undisclosed sales. On the undisclosed sales including transportation receipts, we held net profit rate of 6%. It will be f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , income has to be estimated in a reasonable manner. It will be fair and reasonable to apply N.P. rate of 7.5% on total sales of ₹ 2710000/- estimated by AO. This will give figure of ₹ 203250/-. Thus addition under this head restricted to ₹ 203250/- as against ₹ 2710000/- made by AO. Ground No. 4(ii) is thus partly allowed. 5.5 The deptt is in appeal in relation to relief of ₹ 2506750/- (2710000-203250) and assessee is in appeal before us for application of normal NP rate of 5% in this line of business on undisclosed sales ₹ 2710000/-. The assessee submitted that the appeal of Deptt.is not maintainable because AO has estimated 100% profit on undisclosed sales which is unjudicious because while estimating profit on undisclosed sales AO s approach should be honest and reasonable. The assessee therefore submitted that departmental appeal on this ground deserves to be dismissed. So far as assesses s ground of appeal is concerned, the assessee submitted that in the case of Smt. Meena Somani in the similar circumstances the Hon ble CIT(A) has applied 5% rate on undisclosed gitti sales. Ignoring the assessee's earlier submission and in order to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d that separate addition of ₹ 104284/- is not justified and the same is directed to be deleted. Ground No. 4(iv) is thus allowed. 6.5 Being aggrieved deptt is in appeal. The assessee submitted that these two persons are labour contractors engaged for Lime Stone Mines Jharai to whom payment of ₹ 89900/- is made on 11 occasions. As unrecorded Lime Stone Business income has been taxed separately, hence this addition is uncalled for. It is therefore submitted by the assessee that this ground of appeal of deptt. be dismissed. 6.6 After hearing both the parties, we feel that the ld. CIT(A) was justified in deleting the addition on account of advance of ₹ 1,04,284/- 7.1 The ground of appeal no.(v) of Deptt. reads as under:- The learned CIT(A) erred in deleting addition on account of unrecorded advances at ₹ 320000/-. 7.2 During hearing of the group case, it was argued by the assessee that in Annexure- 24 contains financial activities of Smt.Meena Somani from assessment year 2002-03 to 2009-10 were appearing. It was also submitted by the assessee that origin of the Annexure- 24 is assessment year 2002-03. The assessee submitted that action u/s 148 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 77; 320000/-. The learned AO did not appreciate this fact that investment was already disclosed by Smt.Meena Somani in her books of accounts Smt. Meena Somani during assessment proceedings had submitted that Annexure-24 pertains to her business activities and myself and my son Ritesh Somani were also telling the same thing. The learned AO has accepted the interest ₹ 861287- disclosed by Smt. Meena Somani in her assessment. One income is to be taxed at one place only. I may also submit that while completing assessment u/s 143(3) for Ass.Year 2008-09 in case of Smt. Meena Somani the learned AO has accepted the returned figures of loans and interest on loans and did not made any additions like earlier years. Copy of order is enclosed vide Annexure-H to this letter. In view of these facts I submit additions in my hands are uncalled for and it may be deleted. 7.4 The ld CIT(A) also verified these advances and interest from Smt.Meena Somani s records and he deleted the addition with following observations- From the perusal of records it is found that it was claimed by appellant during the course of survey proceedings as well as assessment proceedings that transactions reco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... all entries from Ass. Year 2002-03 to 2008-09 and did not found any wrong therein (PB 241 to 250). 7.8 In view of aforesaid facts, the assessee submitted that order of ld CIT(A) does not call for any interference and this ground of appeal of Deptt. be dismissed. 7.9 We have heard both the parties. This issue has been considered in the case of Smt. Meena Somani and Shri Ritesh Somani. In that cases, we have confirmed the findings of the ld. CIT(A). Following our findings, we hold that the ld. CIT(A) was justified in deleting the addition on account of unrecorded advance of ₹ 3.20 lacs. 8.1 The ground of appeal no.(vi) of Deptt. reads as under:- The learned CIT(A) has erred in deleting addition on account of protective investment at ₹ 300000/-. 8.2 The facts are similar to the facts as per ground of appeal No. (v) of Department and submissions of the assessee are also the same. 8.3 The Hon ble CIT(A) also verified it from Smt.Meena Somani s records and he deleted the addition with following observations- As mentioned earlier, transactions recorded in annexure-24 were claimed to be belonging to Smt.Meena Somani. AO is directed to examine whether th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of which no disallowance is justified for element of personal use. The .disallowance of ₹ 19962/-out of depreciation is directed to be deleted. The very nature of telephone expenses and vehicle expenses are such that element of personal use is invariably present. However the disallowance made by AO is on the higher side. AO is directed to restrict disallowance out of telephone expense to ₹ 5000/- and disallowance out of vehicle expenses to ₹ 20000/-. Ground No.5 is thus partly allowed. 9.5 Being aggrieved, the Deptt.is in appeal before us 9.6 The ld. DR relied upon the order of the AO.. 9.7 The assessee submitted that ld CIT(A) has deleted disallowance of depreciation which is based on decision of this Hon ble Bench in case of ITO Vs. Awadesh Katta (2010) XLVI Taxworld 85 (JP). The assessee therefore submitted that there is no case of deptt in relation to ground no.(viii) So far as other 2 grounds are concerned the ld CIT(A) has given relief taking disallowance from telephone expenses at ₹ 400/- per month and on Car Maintenance at ₹ 1600/- per month on account of personal use. The assessee is of 70 years of age and has small family with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d (c) as in case of regular books also once books are rejected whether specifically or impliedly NP rate is to be applied and provision of sec.194 read with sec.40a(i)(a), are not applicable. Reliance in this regard is made on Choudhary Bros.vs.ITO (2011) 135 TTJ 55 (JP) (UO). We therefore request your honour to delete the addition. 11.4 The ld CIT(A) decided this issue vide para 5.3 of his order which reads as under:- As mentioned by AO himself in the assessment order, freight expenses of ₹ 530714/- in respect of unaccounted business of appellant. These expenses have not been claimed by the appellant in his books of accounts and therefore the same cannot be disallowed. Even otherwise books of accounts of appellant have been rejected by AO and income has been estimated by applying profit rate. In such a situation also, no further disallowance is justified u/s 40(a)(ia). Addition of ₹ 530714/- is directed to be deleted. Ground No. 5(i) is thus allowed. 11.5 Being aggrieved Deptt.is in appeal before us. 11.6 The ld. DR relied upon the order of the AO 11.7 The assessee in this regard submitted as under:- (i) The AO has made addition u/s 194C. In my c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 122000/- and applying NP rate of 7.5% thereon as against normal rate applied in other comparable cases. GOA no.5 of Deptt.- The learned CIT(A) erred in deleting addition of unrecorded Lime Stone business at ₹ 1037850/- 14.2 We have heard both the parties. These issues have been decided by us while disposing of the appeal of the assessee for the assessment year 2004-05. We have directed to apply net profit rate of 5%. Accordingly the ground of appeal no 2(ii) of the assessee is partly allowed and ground of appeal no. 5 of the Department is dismissed. 15.1 The ground of appeal no. 3 of the deptt. reads as under:- The learned CIT(A) erred in deleting addition on account of unrecorded payment at ₹ 626524/- 15.2 The AO has dealt these addition in para 5 of assessment order which has been reproduced by Hon ble CIT(A) in his order and which reads as under:- In para 4 of questionnaire it is asked to the assessee to explain the payment made to Shri Allanur of ₹ 778724/-, in his reply the assessee has explain that the amount is struck of before survey as the a/c did not exist. However, it is also stated by the assessee that he has paid amount for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 121 Total: 626524 During the course of assessment proceedings we submitted to the learned AO that these expenses were wrongly debited to Allanoor's account which were latter transferred to different accounts. However the learned AO did not accepted our submissions and made additions of ₹ 77S724/-. We submit that these expenses were never claimed by us as expenses but these were the debits in different accounts. The learned Special Auditors have also mentioned it in their report that these are transfers from one account to another. If by mistake one item is debited in one account and if it is corrected latter, there can not be additions. These entries were never claimed by us as expenses. Besides with rectification in this account, rectification was made in primary record (cash book) also. In view of these facts it is submitted additions are uncalled for and it may kindly be deleted. 15.4 The Hon ble CIT(A) decided this ground in para 7.3 of his order as under:- Regarding these entries special auditors mentioned in their report that these are transfer entries from one ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is to be retained at 1/8th . Thus the disallowance on vehicle expenses at ₹ 10,000/- as confirmed by the ld. CIT(A) is upheld. Assessment year 2006-07 18.1 The ground of appeal no.2(i) of the assessee and ground of appeal no.1 of the Deptt. reads as under:- GOA no.2(i) of the assessee That under the facts and circumstances of the case the learned CIT(A) erred in confirming addition of ₹ 150400/- on account of excessive purchase. GOA no.1 of Deptt.- The learned CIT(A) erred in deleting addition of ₹ 24064/- of unrecorded business of gitti 18.2 During the course of assessment proceedings the learned AO observed that there is difference of ₹ 150400/- in purchases as per accounts and as per papers attached with return of income . He therefore calculated element of profit of ₹ 24064/- thereon and made addition of ₹ 174464/-. 18.3 During the course of appeal proceedings, the assessee submitted as under:- The learned AO has taken unrecorded purchases at ₹ 150400/- as discussed by him in para 6 of assessment order. He further added profit element of ₹ 24064/-thereon thus totaling to ₹ 174464/- and tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Deptt. reads as under:- GOA no.2(ii) of the assessee That under the facts and circumstances of the case the learned CIT(A) erred in confirming estimation of Lime Stone Sales made by learned AO unscientifically at ₹ 1168200/- and applying NP rate of 7.5% thereon as against normal rate applied in other comparable cases. GOA no.2 of Deptt.- The learned CIT(A) erred in deleting addition on account of unrecorded business of Lime Stone at ₹ 1080585/- 19.2 We have heard both the parties. The above issue stands decided while disposing off the appeal for the assessment year 2004-05. Following our findings for the assessment year 2004-05, the AO is directed to apply net profit rate of 5%. 20.1 The ground of appeal no.3 of the Deptt. reads as under:- GOA no.3 of Deptt.- The learned CIT(A) erred in deleting addition on accounted business of Marble of ₹ 188738/- 20.2 During the course of assessment proceedings, the AO founded unrecorded business of marble ₹ 210336/- and therefore he made addition of ₹ 210336/-. 21.1 During appeal proceedings, the assessee submitted as under:- Vide para JO of his order and inconsonance to Annexu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt of ₹ 146666/- 22.2 During the course of assessment proceedings, the d AO found that our vehicle receipts were of ₹ 2201825/- against which expenses of ₹ 1839623/- were there which were very high and therefore he estimated income @ 20% of transportation receipts ₹ 2201825/- and made addition of ₹ 440365/-. While making this addition he did not think it appropriate to provide us deduction of the income already disclosed. Besides he taxed unrecorded JCB Rent ₹ 146666/- separately. 22.3 During the course of appeal proceedings, the assessee fairly admitted that as per P L A/c attached to return of income, his income is from business of gitti supply to railway, plying of dumper /trucks and JCB machine and insignificant sales of marble. The assessee , admitting that profit from gitti business and transportation cannot be segregated, requested to the ld CIT(A) that as his consolidated NP rate on consolidated sales and transportation receipts subject to depreciation and bank interest in Ass.Year 2004-05,2005- 06,2006-07,2007-08 2008-09 was at 9.31%, 9.80%, 17.78%, 12.76% 15.84% respectively which being fairly well additions being uncalled f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 80931/-), which is reasonable. Therefore no further addition in respect of Gitti supply business is justified for this year. Thus AO is directed to delete addition of ₹ 587031/- made by him in respect of transportation business. Ground No. 5(vi) is thus allowed. 22.7 Being aggrieved Deptt. is in appeal before us and the ld. DR relied upon the order of the AO.. 22.8 The assessee submitted that appeal of the Deptt. is not maintainable because out of the 3 options available with ld CIT(A) he has applied the most favourable option to Deptt. The assessee therefore prayed to dismiss this ground of appeal of Deptt. 22.9 We have heard both the parties. Since we had directed to apply the net profit rate on consolidated account and therefore, no further addition on account of unrecorded transportation receipts are to be made. There is no evidence on record in respect of such unrecorded receipts. We therefore, uphold the findings of the ld. CIT(A). 23.1 The ground of appeal no.5 of Deptt. reads as under:- The learned CIT(A) erred in deleting addition on account of unrecorded advances at ₹ 2854918/-. 23.2 We have heard both the parties. The above issue is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ales, hence we feel that ld. CIT(A) was justified in confirming the addition. However, the assessee has not pressed its ground of appeal. 29.1 The ground of appeal no.2(ii) of the assessee and ground of appeal no.3 of the Deptt. reads as under:-2 GOA no.2(ii) of the assessee That under the facts and circumstances of the case the learned CIT(A) erred in confirming addition of Lime Stone Sales made by learned AO unscientifically at ₹ 1557003/- and applying NP rate of 7.5% thereon as against normal rate applied in other comparable cases GOA no.2 of Deptt.- The learned CIT(A) erred in restricting addition on account of unrecorded business of Lime Stone at ₹ 155700/- 29.2 We have heard both the parties. Both these issues stand covered by our findings for the assessment year 2004-05. Following our findings, we hold that AO will apply the net profit rate of 5%. 30.1 The ground of appeal no.2(iii) of the assessee and ground of appeal no.2 of the Deptt. reads as under:- GOA no.2(iii) of the assessee That under the facts and circumstances of the case the learned CIT(A) erred in applying NP rate of 10% on disclosed sales ₹ 3605514/- as against ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Construction Co. vs. ITO 100 'TTJ 1101 (Jd.), ACIT vs. Padamchand Bhansali 85 TTJ 215 (Jd.) Singhal Builders Contractors vs. Add!. CIT 133 TTJ (Jp) 102 (UR). We therefore request your honour to delete the addition of ₹ 200000/-. 32.4 The Hon ble CIT(A) held as under:- It has been held by various judicial authorities that once books of accounts are rejected and income is estimated by applying profit rate, no further disallowance is justified u/s 40A(3). As mentioned earlier, in this case books are not correct and complete and income is estimated by applying profit rate on turnover of appellant. Therefore further disallowance u/s 40A(3) is not justified. Addition of ₹ 200000/- is directed to be deleted. Ground No. 5(vii) is thus allowed 32.5 Being aggrieved Deptt.is in appeal and relied upon the order of the AO 32.6 The assessee submitted that in this case books of accounts have been rejected by AO. Books of accounts are treated as rejected by implication also. The relied upon the decision in the case of Choudhary Brothers vs. ITO 45 TW Page 99 (JP)). Once books are rejected disallowance u/s 40A(3) should not be made. The further relied upon the cas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... GOA no.2(ii) of the assessee That under the facts and circumstances of the case the learned CIT(A) erred in applying NP rate of 10% on undisclosed marble sales ₹ 121013/- as against 5.58% disclosed by the appellant as per Trading account appended with original ROI filed GOA no.3 of Deptt.- The learned CIT(A) has erred in deleting addition on account of unrecorded marble business of ₹ 208324/- 37.2 The issues are the same as have been considered by us for the assessment year 2007- 08. Following our findings, we dismiss the ground of appeal 2(ii) of the assessee as well as ground of appeal 3 of the revenue. 38.1 The ground of appeal no.2(iii) of the assessee and GOA no.2 of the Deptt. reads as under:- GOA no.2(iii) of the assessee That under the facts and circumstances of the case the learned CIT(A) erred in applying NP rate of 10% on undisclosed sales ₹ 4640597/- as against 5.58% disclosed by the appellant as per Trading account appended with original ROI filed GOA no.2 of Deptt.- The learned CIT(A) has erred in restricting addition on account of unrecorded marble sales to ₹ 5107684/- 38.2 This issue has been considere ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; 5,000/-. 43.1 The 10th ground of appeal of the revenue is that the ld. CIT(A) has erred in deleting the addition on account of depreciation on vehicles at ₹ 13,400/-. 43.2 We have heard both the parties. Following our findings for the earlier year, we hold that 1/8th of depreciation on vehicle i.e. car is to be disallowed u/s 38(2) of the Act. 44.1 The 11th ground of appeal of the revenue is that the ld. CIT(A) has erred in restricting the addition on account of disallowance of vehicle expenses to ₹ 7,500/-. 45.1 After hearing both the parties, we feel that the ld. CIT(A) was justified in restricting the disallowance to ₹ 7,500/-. 46.1 The 12th ground of appeal of the Department is that the ld. CIT(A) has erred in restoring back the mater for verification of addition on account of excess depreciation on truck of ₹ 2,71,124/-. 46.2 We have heard both the parties. Since the ld. CIT(A) has restored back the matter, therefore, we don t feel to interfere with the findings of the ld. CIT(A). We confirm the ld. CIT(A) s order in restoring the matter back to the file of the AO. 47 In the result, the appeals of the assessee as well as revenue a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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