TMI Blog2010 (12) TMI 1293X X X X Extracts X X X X X X X X Extracts X X X X ..... ri T.L. Peter, DR Respondent By: Shri G.V.N. Hari, CA ORDER Per Bench: All these appeals, filed at the instance of the revenue, are directed against the orders passed by learned CIT(A),Rajahmundry and they relate to the assessment year 2006-07. In six appeals, the solitary issue urged is identical in nature and in the remaining appeal, besides the common issue stated above, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 120/Vizag/2009 and stated that the instant issue is squarely covered by the said order. 4. The facts relating to the common issue are stated in brief. All these assessees have claimed expenditure on packing material/sales promotion/ gift articles. The Assessing Officer was of the view that tax is required to be deducted under section 194C of the Act on these payments. Since these assessees had ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the case of M/s Devi Fisheries Ltd., and also in the case of Shri Bommana Ramachandra Rao, wherein this Tribunal has categorically held that the main purpose in buying the packing material was to obtain goods for the purpose of packing and the fact that incidentally some printing was required to be done by the supplier was of no consequence; therefore, the provisions of sec. 194C are not attra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aid debit balance. The Assessing Officer did not accept the explanation of the assessee that the other Partner had sufficient credit balances and after setting off of the above said debit balance against the other credit balances of partners, there would still be a credit balance of ₹ 54,35,619/- in respect of capital account of all Partners put together. Accordingly the Assessing Officer wo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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