TMI Blog2020 (9) TMI 1136X X X X Extracts X X X X X X X X Extracts X X X X ..... Co. and not to the Government ? - HELD THAT:- Having considered the concurrent findings, we do not find that, the Tribunal has erred in law and on facts in confirming the decision of CIT (A) deleting the disallowance made under Section 40A(3) of the Act. Hence, we find that, both the authorities have correctly deleted disallowance made by the assessing officer. No interference is called for. Ther ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der passed by CIT(A) - Ahmedabad dated 22.08.2016 for assessment year 2010-11. 3. It is the case of the respondent - assessee, inter alia, that, the respondent is engaging in the business of construction and it had filed income tax return on 14.10.2010 declaring total income as 'Nil' for Assessment Year 2010-11. The original assessment under Section 143 (3) of the Act was made determini ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t, 2002 w.e.f. assessment year 2008-09, verified the copy of the bill of the ld. Solicitor submitted by the respondent assessee and considering the evidence on record, allowed the appeal and disallowance made by the assessing officer under Section 40 (A) (3) of the Act came to be deleted. However, the Tribunal was pleased to partly allow the appeal filed by the respondent assessee on the ground of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... made by the assessee to M/s. C.C.Gandhi Co. and not to the Government ? (iii) Whether the Appellate Tribunal has erred in law and on facts by referring to the written submission of the assessee (reproduced on page 7 of the CIT (A)'s order), which relies on Rule 6DD(j) although Rule 6DD(j) was deleted w.e.f. 01.12.1995 ? Though above substantial questions of law have been raised in this ..... X X X X Extracts X X X X X X X X Extracts X X X X
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