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2017 (12) TMI 1614

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..... was reduced by half by the C.I.T.(Appeals). ITAT gave two reasons to set aside the findings of the A.O. – C.I.T.(Appeals). Firstly, that the books of account were not rejected and secondly, that in the past, consistently such expenses were allowed in scrutiny assessments. In the case of labour cases too, identical reasons were adduced by the A.O. to bring to tax a sum of ₹ 2.2 crores. Th .....

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..... (u/S.5 of Limitation Act) ITA No.1187/2017 CM No.47029/2017 1. The Revenue is aggrieved by the findings of the Commissioner of Income-Tax (Appeals) and Income Tax Appellate Tribunal (ITAT), whereby disallowances and consequent additions made on two counts, i.e. expenses claimed towards the bricks, machinery repair, cartage etc. (Rs.1.1. crores) and labour expenses (Rs.2.3 crores) were set .....

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..... ITAT. 4. This Court is of the opinion that the principal reasoning of the ITAT, i.e. omission to reject the books of account, in which event the adhoc disallowance could have been adjusted and also the historical treatment of such expenses, cannot be termed as unreasonable; in support of its ultimate conclusion. 5. In these circumstances, no substantial question of law arises. 6. The App .....

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