TMI Blog2019 (7) TMI 1262X X X X Extracts X X X X X X X X Extracts X X X X ..... er was returned. AO neither examined Sri Murali Krishna nor examined Sri Srisaila Babu and the reasons for not producing the evidence at the time of search or post search and the assessment proceedings. Therefore, we are of the considered opinion that the issue was not properly verified by the lower authorities to find out the source and the receipt of the amount. It is incumbent upon the AO to verify the bank accounts of the assessee with matching dates of advance as well as the bank accounts of Sri L. Murali Krishna with matching dates for the sources of both the parties. Therefore, we are of the view that the issue needs detailed examination to verify the sources with the bank accounts of the assessee, Sri Murali Krishna and other corroborative evidences. Hence, we are of the considered opinion that the issue should be remitted back to the file of the AO to make detailed examination and decide the issue afresh on merits. - The appeals of the revenue and cross objections of the assessee for the A. Y. 2008-09 and 2009- 10 on this issue are allowed for statistical purposes. Disallowance of expenses as Direct work expenditure, General Expenses and EPUI Expenses - CIT(A) allo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ary evidence. Accordingly we reject the argument placed by the assessee that the pro-notes are not financial transactions. We have gone through the pro-notes, the pro-notes are written very clearly that the recipient has received a sum of ₹ 50. 00 lakhs each on 01. 07. 2011 from R. Sulochana Devi and Sri R. Venkatramaiah and as per the contents of the pro-notes, they are genuine transactions with complete details on the pro-notes. Since the valid pro-notes are available with the assessee, during the course of search, as per section 292C of the Act, it is presumed that the assessee had given loans to Sri R. Muthaiah. Since the assessee failed to prove that the pro-notes were obtained only for the purpose of security, we have no hesitation to hold that the promissory notes of ₹ 1. 00 crore (50. 00 lakhs each) on 01. 07. 2011 are genuine transactions, accordingly we uphold the order of the CIT(A) and dismiss the appeal of the assessee. Telescopic benefit - Set off of addition made by the AO relating to pronotes against the undisclosed income admitted by the assessee - HELD THAT:- The assessee has claimed for the set off of addition made by the AO against the additi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ngaged in the business of civil contract works. The case was taken up for scrutiny, notices u/s 153A, 143(2) and 142(1) were issued and the assessments were completed u/s 143(3) r. w. s. 153A of the Act. During the search conducted in the residential premises of the assessee, incriminating material was found and the assessments were completed u/s 153A r. w. s. 143(3) by an order dated 31. 03. 2014. The year wise breakup of the returns filed in response to the Notice u/s 153A for the A. Y. 2008-09 to 2011-12 are as under: Asst. Year Date of Filing Total income admitted Agricultural income 2008-09 24. 05. 2013 23,35,550/- 7,50,000/- 2009-10 47,40,700/- 8,50,000/- 2010-11 23. 05. 2013 99,43,060/- 8,50,000/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s Colony, Jubilee Hills, Hyderabad for a consideration of ₹ 1. 10 crores. Further perusal of the seized material bearing No. Annexure A/RV/01 marked as page No. from 24 to 29 contain the copies of the receipts of cash payments made to Shri L. Murali Krishna and Sri Sailababu for purchase of the property as per the details given under : Page No. Date Amount (Rs. ) Description 24 04/04/2008 15 lakhs Sri Murali Krishna received the amount from Smt. R. Sulochana Devi 25 02/02/2008 20 lakhs Sri Srisaila Babu (GPA holder) received the amount from Smt. R. Sulochana Devi 26 14/01/2008 30 lakhs Sri Srisa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from the seller and failed to explain the sources for payment of ₹ 1. 95 lakhs. Out of which the payment of ₹ 180. 00 lakhs was related to the F. Y. 2007-08, relevant to the A. Y. 2008-09 and the payment of ₹ 15 lakhs was related to the F. Y. 2008-09, relevant to the AY. 2009-10. The AO has considered the explanation of the assessee and given a finding that the assessee failed to furnish any confirmation letter from Sri L. Murali Krishna and failed to prove the genuineness of the transactions with relevant material evidences. Since the assessee failed to prove the sources for payment of ₹ 195. 00 lakhs, the AO treated the entire sum of ₹ 195. 00 lakhs as undisclosed income for the A. Y. 2008-09 and 2009-10 and assessed to tax. The AO made the addition of ₹ 180. 00 lakhs for the A. Y. 2008-09 and ₹ 15. 00 lakhs for the A. Y. 2009-10. 3. Aggrieved by the order of the AO, the assessee went on appeal before the CIT(A), filed the written submissions and the additional grounds. The Ld. CIT(A) called for the remand report which was submitted by the AO. Subsequently the assessee filed rejoinder on the comments of AO. The Ld. CIT(A) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... O. The Ld. AR also furnished the account copy of Sri L. Murali Krishna in his books of accounts in page No. 81 of the paper book, showing the payments and the receipts. The assessee also submitted confirmation from Sri L. Murali Krishna, confirming the advance paid and the amounts received back from him. He argued that in the instant case, there is no unaccounted investment or unaccounted payments. The entire payment of ₹ 180 lakhs for the A. Y. 2008-09 and ₹ 15 lakhs for the A. Y. 2009-10 was duly recorded in the books of accounts of relevant assessment years. Hence, the payments were made out of accounted sources of the assessee and the entire amount was received back from the builder, therefore, there is no case for making the addition either as undisclosed investment or as unexplained source. The Ld. AR further submitted that the assessee has furnished additional evidence before the Ld. CIT(A) and the Ld. CIT(A) has called for the remand report from the AO. The AO has examined the entire issue and given a report stating that an advance amount of ₹ 195. 00 lakhs to Sri L. Murali Krishna was declared in the return of income of the assessee as well as Sri L. Mura ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... port stating that the contention of the assessee with regard to source and return of money appears to be reasonable. On the basis of the remand report, the Ld. CIT(A) deleted the addition of ₹ 195. 00 lakhs. In this case, as observed from the assessment order, the assessee neither produced the books of accounts nor produced any evidence before the investigation team during the course of search or subsequent to the search. During the course of assessment proceedings also, the assessee failed to produce any evidence to explain the source for payment. In the instant case, the receipts are available evidencing the payment to the builder but no other documents are available at the time of search in the residential premises, evidencing the repayment of the amounts advanced to Sri L. Murali Krishna. There was no agreement or an iota of evidence available in the premises. Having not produced any evidence during the course of search or post search proceedings and failed to produce the books of accounts and confirmation during assessment proceedings, mere oral statements without furnishing the corroborating evidence is not sufficient to hold that the source for the advances are explain ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ties to find out the source and the receipt of the amount. It is incumbent upon the AO to verify the bank accounts of the assessee with matching dates of advance as well as the bank accounts of Sri L. Murali Krishna with matching dates for the sources of both the parties. Therefore, we are of the view that the issue needs detailed examination to verify the sources with the bank accounts of the assessee, Sri Murali Krishna and other corroborative evidences. Hence, we are of the considered opinion that the issue should be remitted back to the file of the AO to make detailed examination and decide the issue afresh on merits. The assessee is directed to submit the details before the AO to complete the proceedings at the earliest. The AO is directed to give sufficient opportunity to the assessee to explain the case. Accordingly, the appeals of the revenue on this ground and cross objections of the assessee for the A. Ys. 2008-09 and the A. Y. 2009-10 are set aside and remitted back to the file of the AO. and allowed for statistical purposes. The appeals of the revenue and cross objections of the assessee for the A. Y. 2008-09 and 2009- 10 on this issue are allowed for statistical purpos ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al Expenses; in A/RV/PO/7, page 14 contains Work Related Expenditure ; In A/RV/PO/14,, page 16 contains, Work related Expenditure . All these are payments made to technically qualified people who assisted us in the execution of EPC (Engg. Procurement and Construction) contracts allotted to us. These payments have been accounted in the books of account under the relevant expenditure head and disclosed under the grouping Direct Work Expenditure in the P L account. Q. No. 5 : Please produce the bifurcation of Direct Expenditure? Ans : We will submit the details shortly. Q. No. 6 : Do you want to say anything else? Ans : Under the Direct Work Expenditure, I admit that there were certain payments made to individuals. Many people approach us for getting the things done and promise to help us in completion of our work. These payments were made to those persons who promised us to get the things done for us in expeditious manner. However, I am not very sure whether these payments are backed by proper vouchers. I shall come forward and offer such expenditure as disallowable. 8.1. The assessee fai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 392, 393, 395, 397 59, A/RV/PO/06 page number 207 to 209, A/RV/PO/07 page No. 192, the assessee has claimed deduction towards General Expenses to the extent of ₹ 63,04,108/- and the year wise breakup is as under : F. Y. A. Y. Amount (Rs. ) 2006-07 2007-08 29,74,800 2007-08 2008-09 7,63,308 2008-09 2009-10 11,71,000 2009-10 2010-11 13,95,000 Total 63,04,108 In the statement recorded on 10. 04. 2012, in question No. 6, the assessee accepted to come forward for admission of expenditure as disallowable. The AO issued show cause notice as to why the amount of ₹ 63,04,108/- should not be disallowed in the respective a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e A. Y. from 2008-09 to 2011-12 as under : A. Y. Amount (Rs. ) 2008-09 10,52,500 2009-10 6,88,000 2010-11 6,25,000 2011-12 2,00,000 Total 25,65,500 9. Aggrieved by the order of the AO, the assessee went on appeal before the CIT(A) and the Ld. CIT(A) has called for the remand report and in the remand report, the AO stated in para No. 7. 1, that the assessee did not furnish the details of persons to whom the above amounts were paid falling within the term direct work expenditure were paid, viz, names and addresses of the recipients, nature of services rendered by them, confirmation of receipt of such payments, whether such expenditure was directly related to business or those represented unlawful payments so as to motivate the persons concerned with the work allotted to hi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... man can engage in contact work without claiming such expenditure. Naturally such situation is not possible In this tine of business. Therefore; it can reasonably be presumed that the appellant would have camouflaged such expenses (IS heads) into 10 heads. It is not the case where the appellant has not expended the monies on these heads of account (15). It is not the case of Assessing Officer that the expenses recorded in the seized material has net been found or plugged into the books in some account or other. It is also not the case of the Assessing Officer that any unaccounted investment was made out of such expenditure. This finding was not given by the Assessing Officer in the order. I have examined the P L account. There are two major heads namely Direct expenditure and Indirect expenditure. The monies are ultimately withdrawn from the banks and expenditure was incurred. Such expenditure is ultimately booked as either Direct work expenditure or Indirect expenditure in the P L account. Such expenditure debited to the P L account per se is not disallowable unless proved otherwise. In the instant case, it is not possible to say with certainty that the entire expenditure is allow ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion from the Assessing Officer. Financial Assessment Amount 2007Year-08 Year 2008 -09 nt 6,65,0 2008-09 2009-10 42,63, 2009-10 201011 45,10, 2010-11 2011-12 27,68, 2011-12 2012-13 34,06, Total 1,56,1 (ib) The material seized vide Annexures- A/RV/PO/3 (Page Nos 300 to 304),A/RV/PO/4 (Page Nos 108, 44 to 47, 19, 28), A/RV/PO/6 (Page Nos 35 to 40, 73 74), A/RV/PO/7 contains the expenditure incurred under the head ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A. Y. Amount (Rs. ) 2006-07 2007-08 29,74,800 2007-08 2008-09 7,63,308 2008-09 2009-10 11,71,000 2009-10 2010-11 13,95,000 Total 63,04,108 (iiib) It is the case of the Assessing Officer that the appellant has not maintained any vouchers for such expenses which fact was confirmed in the statement recorded from the appellant The Assessing Officer has disallowed the expenditure in the absence of corroborative evidence. (iiic) It is the case of the appellant that the said expenses were recorded under the head 'direct work expenditure' in the P L account for the respective years. The expenses are part of memoranda of books of account forming part of regul ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... penditure as not allowable being unexplained expenditure. The total expenditure claimed for the Asst Year 2008-09 to 2010-11 is ₹ 63,04,108/- Accordingly, 50% of it would be ₹ 31,52,054. iv ) EPL Expenditure/ Illegal payments : (iva) It is the case of the Assessing Officer that there are certain expenditure which is termed as work related such as EPC expenses (Engineering Procurement and Construction) for which no supportive vouchers are available. It is also the case of the Assessing Officer that the appellant was awarded contract with MIs Engineering Projects India Ltd. The details of expenses are recorded in seized material vide Annexure-A/RV/PO/ 3 to 14 (Para 5 of the assessment order). The Assessing Officer has made the calculation as under. F. Y. A. Y. Amount (Rs. ) 2006-07 2007-08 10,52,500 2007-08 2008-09 6,88,000 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3,44,000 2009-10 3,12,500 2010-11 1,00,000 Total 12,82,750 9.1. The assessee also filed cross appeals agitating disallowance confirmed by the CIT(A) and cross objection supporting the order of the Ld. CIT(A) for confirming 50% of the addition for all the assessment years. During the appeal hearing, the Ld. DR argued that during the course of search, seized material was found indicating the payments, which was grouped under general expenses, direct expenses and EPC expenses. During the course of search, the assessee accepted that the payments were not supported by proper evidence and also agreed to come forward with disallowance. No evidences were filed with regard to the name and address of the persons to whom the amounts were paid, nature of expenses, purpose of payment etc. During the appeal proceedings also, the assessee did not produce such details, which is evident from the remand report also. No evidence whatsoever was filed by the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... premises of the assessee, certain incriminating material was available showing expenses incurred for the A. Y. 2008-09 to 2012-13 which was grouped under the head Direct Expenditure , general expenses and EPI expenses. The assessee failed to produce any evidence to support the payments made in respect of the various payments. The Ld. AR during the appeal hearing accepted that the entire expenditure was made out of the self contained vouchers and there were no proper vouchers available with the assessee to support the genuineness of the expenditure. In the statement recorded u/s 132, the assessee had agreed that the payments were made to the persons who promised to get the things done in an expeditious manner. Names of the persons to whom the payments were made, what was the work done by the person, nature of service rendered by the said persons was not explained by the assessee. Whether the payments were made in regular course of business or for illegal payments was also not furnished by the assessee. Though in response to question No. 5, the assessee stated that the payments were made to technically qualified people, who assisted in execution of the EPC contracts, the assessee n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Amount as per seized material Amount as per regular books of accounts Difference Income tax return 1. Diesel Account 22,13,128. 00 75 to 78 22,13,128. 00 -- 22,13,128. 00 Oil Account 1,78,410. 00 99 1,788,410. 00 16,37716. 40 15,859,306. 40 2. Mess Maintenance Account 3,00,602. 22 91 to 93 3,00,602. 00 62,3071. 00 3,22,469. 00 3. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ys 2008-09 to 2012- 13. I. T. A. No. 609/Viz/2018, A. Y. 2012-13 12. Ground No. 1 and 7 are general in nature which does not require specific adjudication. 13. Ground No. 2 is related to the deletion of addition made towards pronotes for an amount of ₹ 50. 00 lakhs which was set off against the disallowance of expenditure. During the search u/s 132 in the case of the assessee, certain pro notes were found and seized as annexure A/RVR/2, pages serially numbered 195, 196, 198 199 which contain the details of amounts advanced to Sri R. Muthaiah as per the details given below : Page No. Name of the Lender Date Amount 195 Smt. R. Sulochana Devi 01/07/2011 50 Lakhs 196 Sri R. Venktramaiah 01/07/2011 50 Lakhs 198 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nsactions and clarify whether these are reflected in your books of account, if so please produce the evidences there of? Ans : I confirm that,I have signed and executed the following pro-notes asmentioned at pages serially numbered 195, 196, 198 199 of seized folder marked as A/RVR/2 from the residence of Sri Ravulapalli Venkatramaiah Date of pronote Amount Seized Reference 01/07/2011 50 lakhs Page 195 01/07/2011 50 Lakhs Page 196 07/10/2011 25 lakhs Page 198 20/10/2011 25 lakhs Page 199 On 01/07/2011, I have executed two pronotes worth Rs, I Crore in favour of Sri P. Venkatramaiah and his wife Smt. Sulochana Devi which are not financial transactions. It is only to secure Mr. R. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the pro-notes of ₹ 50. 00 lakhs do not represent any advance given by the assessee and it is only paper transaction and does not deserve to be treated as unexplained investment in the hands of the assessee, therefore requested to delete the addition. However, the AO did not find the explanation offered by the assessee as convincing, hence, treated the sum of ₹ 50. 00 lakhs as unexplained investment and taxed the same in the hands of the assessee. 14. Aggrieved by the order of the AO, the assessee went on appeal before the CIT(A) and the Ld. CIT(A) confirmed the addition made by the AO. However, allowed the sum of ₹ 50 lakhs as telescopic benefit for the additional income offered by the assessee in the A. Y. 2011-12. For the sake of clarity and convenience, we extract relevant part of the order of the Ld. CIT(A) from page No. 21 to 23 which reads as under: A cursory look at the pro-notes reveals the following facts : The first set of pro-notes were executed on 07. 10. 2011. The rate of interest charged at 24%. Apparently, the Executant acknowledged the receipt of cash of ₹ 50,00,000/-. Prima facie the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot bring such facts. It remains a mere isolated statement. (e) Further, I have also perused the statement recorded from Sri R. Muttaiah on 19/04/2012 wherein he stated that the pro-notes were not torn since they have no value. I have examined this aspect. I am of the opinion that the Executant has no legal remedy if the lender pressed for legal action in any Court of Law owing to the signature appended by the Executant. The burden of proof shifts on Sri R. Muttaiah to prove that money was not received against the acknowledgement. Thus, the probability of ignoring the instruments is remote and unconvincing. The assertion of executants of pro-note is definitely an afterthought engaged in order to orchestrate the view of the appellant. Further, the material evidence as to Executant's role in Delhi-Agra road project, the corroborative evidence necessitating the alleged arrangement was not brought on record. There is no Law preventing Mr. Muttaiah to mention the purpose being guarantee on the pro-note instead of mentioning the rate of interest and receipt of cash on 01/07/2011. In view of the facts and inconsistencies mentioned above, the argument of the appell ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 54 A cursory look at the details of pro-notes clearly establishes the fact that the pro-notes were executed against the receipt of cash of ₹ 25,00,000/- each on different dates. The pro-notes were executed by Sri Muttaiah. The rate of interest is 36%. The pronotes are duly signed by the Executant. I have gone through the statement recorded from Sri Muttaiah on 19/04/2012 wherein he confirmed that a loan of ₹ 50,00,000/- was borrowed from Sri Ravulapalli Venkatramaiah and it is still outstanding. This fact was also confirmed by Sri Ravulapalli Venkatramaiah in his statement recorded on 11/01/2012 Thus, the pro-notes are considered as explained (f) Alternatively, the appellant had pleaded for telescoping of additional income of₹ 50,00,000/- offered by the appellant for the Assessment Year 201112. The appellant had relied on the ratios of following cases in support of his claim : CIT vs. Venkateswara Timber DepOt ( 222 ITR 768, AP HC] CIT vs. K. S. M. Guruswamy Nadar Sons [149 ITR 127, Mad HC] Gopal S Pandith vs DCIT [186 TTJ 64, Bang Tri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Mere oral statement cannot discard the evidence found during the course of search in the premises of the assessee. Therefore, it is assessee s burden to prove that the pro-notes are not financial transactions and the pro-notes represent only paper transactions for the sake of security. With oral statement and affidavits, the assessee cannot get away from taxing the unexplained investment. Therefore, argued that the Ld. CIT(A) rightly directed the AO to tax the sum of ₹ 50 lakhs in the hands of the assessee and the remaining ₹ 50 lakhs in the hands of Smt. R. Sulocahna Devi. However, the Ld. CIT(A) allowed the addition of ₹ 50 lakhs in the hands of the assessee to be set off against the additional income offered by the assessee for the A. Y. 2011-12 which is incorrect. The Ld. DR further submitted that though the assessee had offered the additional income for the A. Y. 2011-12, that was offered for the excess expenditure which was already spent by the assessee and there were no funds available for the assessee for advancing the amounts to Sri Muthaiah. Further, the Ld. DR argued that the assessee s contention is contradictory. One way, the assessee contended that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me required to be set off against the additional income admitted by the assessee for the A. Y. 2011-12. Hence, argued that even otherwise also, the Ld. CIT(A) has rightly allowed telescopic benefit and no interference is called for. 18. We have heard both the parties and perused the material placed on record. In this case, during the course of search u/s 132, pro-notes drawn in favour of Smt. R. Sulochana Devi on 01. 07. 2011 for ₹ 50 lakhs bearing interest @24% and Sri R. Venkatramaiah on 01. 07. 2011 for ₹ 50 lakhs @24% and Sri R. Venktramaiah on 07. 10. 2011 and 20. 10. 2011 for ₹ 25 lakhs @36% were found and seized from the residential premises of the assessee. In the statement recorded on 11. 01. 2012, the assessee explained that the pro-notes were taken for the purpose of security in the tender process of HSNL work, with regard to pro-notes for ₹ 25 lakhs each on 07. 10. 2011 and 20. 10. 2011 was accepted by the assessee as well as the executant of the pro-notes, therefore, there is no dispute. A statement u/s 131 was recorded from Sri R. Muthaiah, executant of the pro-notes who has stated that the pro-notes were given as performance gu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eory of the assessee as well as the executant of the pro-notes that the pro-notes were not financial transactions and they are only paper transactions given for security in the absence of any documentary evidence. Accordingly we reject the argument placed by the assessee that the pro-notes are not financial transactions. We have gone through the pro-notes, the pro-notes are written very clearly that the recipient has received a sum of ₹ 50. 00 lakhs each on 01. 07. 2011 from R. Sulochana Devi and Sri R. Venkatramaiah and as per the contents of the pro-notes, they are genuine transactions with complete details on the pro-notes. It was also mentioned the rate of interest, date of receipt, sum of receipt and acknowledged having received the money. The pro-notes were not cancelled and there was no evidence to show that the pro-notes were given as security. The Ld. AR argued that the pro-notes does not contain signature of the witnesses. As per the Negotiable Instruments Act, the witness s signature is not mandatory to hold that the promissory note as valid. As per section 4 of the Negotiable Instruments Act, the requirement is, drawer should sign the promissory note in writing, p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income disallowing the expenditure. It is seen from the statement of computation of income that the sum was spent and there was no cash balance or generation of cash made out of the disallowance of expenditure. The assessee, even during the appeal hearing also did not explain how the assessee could generate the cash by disallowing the expenditure which was already spent. Though the disallowance of expenditure is hidden the addition, the assessee must explain the modus operandi of inflation of expenditure under each head and also explain the generation of cash for advancing the amount out of sums saved from the inflation of expenditure. In the absence of such details, it is not correct to allow telescopic benefit, hence, we set aside the order of the Ld. CIT(A) and restore the order of the AO. Accordingly, appeal of the revenue is allowed and CO of the assessee is dismissed. 22. The next issue in this appeal is confirmation of addition on account of illegal payments under the head Direct Expenses, General Expenses and EPC expenses. The AO disallowed the sum of ₹ 34,06,750/- for not producing the relevant evidences. The Ld. CIT(A) restricted the disallowance to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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