TMI Blog2022 (8) TMI 487X X X X Extracts X X X X X X X X Extracts X X X X ..... time of hearing. As submitted that this has continued even in the subsequent years i.e. Assessment Year 2016-17 to 2018-19 wherein the Ld. AO in the scrutiny assessment treated the assessee as a mutual association and accordingly has accepted Principle of Mutuality in respect of majority of receipts as claimed by the assessee. Taxability of Catering Revenue - addition made on account of club share income of assessee from caterer, on the ground that the same was exempt under principle of mutuality - HELD THAT:- Hon'ble Bombay High Court [ 2019 (6) TMI 447 - BOMBAY HIGH COURT] has affirmed the finding of this Tribunal in allowing 'Catering Revenue' as income exempt from tax under the principle of Mutuality. Hence, the said issue of applicability of mutuality principle is further covered/ settled in favour of assessee. Hence the observation made by the ld. PCIT in this regard is totally untenable in the eyes of law. Revenue from holding Cricket Matches - Hon'ble Supreme Court in assessee's own case [ 1968 (8) TMI 200 - SUPREME COURT] had duly considered the issue relating to holding of cricket matches and had clearly laid down that the activity of cric ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dy held hereinabove that the view taken by the ld. PCIT is grossly incorrect on various counts. In any case, once a possible view has been taken by the ld. AO in the assessment proceedings, the same cannot be subject matter of revision by the ld. PCIT in the section 263 proceedings, merely because the ld. PCIT is of a different view on the same set of facts. Reliance in this regard is placed on the decision of Hon ble Jurisdictional High Court in the case of CIT vs. Gabriel India Ltd. [ 1993 (4) TMI 55 - BOMBAY HIGH COURT] which has been approved by the Hon'ble Supreme Court in Malabar Industrial Co Ltd vs. CIT [ 2000 (2) TMI 10 - SUPREME COURT] PCIT has directed the conduct of a roving and fishing inquiry which is not permissible in law - Merely calling for information to see whether there is potential reason to hold that assessment erroneous and prejudicial to the interest of revenue, constitutes a roving or fishing inquiry. Reliance in this regard is placed on the decision of Hon ble Delhi High Court in the case of CIT vs. International Travel House Ltd [ 2010 (9) TMI 347 - DELHI HIGH COURT] it has been held that the PCIT is not permitted to exercise his revisional ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... acts of the case, the provisions of Income Tax Act, 1961, and the Rules made thereunder. 1.(e) On the facts and in the circumstances of the case and in law, the learned Commissioner of Income Tax erred in passing the order u/s. 263 of the Income Tax Act, 1961 on a ground of complete absence of application of mind by assessing officer and thereby erred in treating order of assessment perverse erroneous and prejudicial to the interest of the revenue which is wrong an contrary to the facts of the case, the provisions of Income Tax Act, 1961, and the Rules made thereunder. 1.(f) On the facts and in the circumstances of the case and in law the learned CIT erred in not appreciating the position in law that the suo-moto revisional authority is not empowered to substitute his own judgement for that of the subordinate officer unless the decision of the subordinate officer held to be erroneous, perverse or contrary to law. 2.(a) On the facts and in the circumstances of the case and in law the learned CIT grossly erred in passing the order u/s.263 of the Income Tax Act 1961, by raising an entirely new issue which was never raised in any of the two show cause notices dated 19.01.2015 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tsiders to enjoy the benefit of amenities and facilities of the appellant club otherwise available to non-temporary members. 3.(c) On the facts and in the circumstances of the case and in law, the learned Commissioner of Income Tax erred in giving a finding that none of the receipts of assessee whether in the form of contributions by members as fee or subscription or by way of charges for particular game or sports shall be exempt from taxation which is wrong and contrary to the facts of the case, the provisions of Income Tax Act, 1961, and the Rules made thereunder: 3.(d) The ld.CIT failed to appreciate that existence of different classes of membership having varying subscription rates, rights and entitlements to facilities/surplus does not affect the principles of mutuality in term of Bombay High Court decision in case of CIT Vs. Willingdon Sports Club (302) ITR 279). 3.(e) On the facts and in the circumstances of the case and in law, the learned Commissioner of Income Tax failed to appreciate that entitlement of certain classes of members to sharing of surplus on dissolution cannot be the reason/ ground to deny the benefit of principle of mutuality. 3.(f) The ld. CIT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and the Rules made thereunder. 4.(b) On the facts and in the circumstances of the case and in law, the learned Commissioner of Income Tax erred in not appreciating the fact that assessee does not carry on any trade or commerce and is a sports/social club established with the object for mutual benefit among its members and for mutual interest. 4.(c) On the facts and in the circumstances of the case and in law, the learned Commissioner of Income Tax failed to appreciate that appellant club is mainly established for promotion of cricket in India and accordingly conducting international cricket matches and IPL matches at its own stadium i.e. the Brabourne stadium is in accordance with the objects of the appellant club. 4.(d) On the facts and in the circumstances of the case and in law, the learned Commissioner of Income Tax erred in stating that the appellant exists primarily for promotion of game of cricket and the running of club is a secondary object, without appreciating that international cricket matches have been hosted by the appellant club at its own venue after many years. 4.(e) The Id. CIT erred in observing that the AO failed to look into aspects of mutuality in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ces of the case and in law the learned CIT erred in directing the A.O. to investigate into the matter of claiming the interest income and capital gain as exempt income under principle of mutuality without appreciating that the said claims have been suo-moto withdrawn in the assessment proceedings u/s. 143(3) before the ld. AO. 7.(a) The learned CIT has erred in issuing notice w/s.263 on frivolous presumption and then directing A.O. to verify the presumption and give definite finding on the same. Such directions are illegal and not tenable in law. 7.(b) The ld. CIT erred in making various irrelevant and frivolous observations particularly that: (i) the assessing officer was misled to believe that assessee was not undertaking any activity involving profit in assertion that it does not carry any trade or business . (ii) the assessee has deliberately misguided assessing officer so as to refrain him from looking into the new activity of International Cricket matches conducted at assessee's premises after 36 years and IPL matches held here. (iii) the maintenance of the ground and the pitches in a systematic manner, provision of various facilities including flood ligh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uding expenses costs and charges in the event of the company being wound up. The assessee is claimed to be a mutual concern income of which is not chargeable to tax on principles of mutuality. This claim has been accepted in the past by the revenue. 3.1. The return of income for the Asst Year 2010-11 was filed by the assessee on 15.10.2010 declaring a total income of Rs. 1,93,57,341/-. The assessment u/s. 143(3) was completed vide order dated 30.03.2013 assessing the total income at Rs. 5,98,30,570/-. The said assessment was completed after taking into consideration the various submissions made by the assessee vide various letters in response to notices issued u/s. 143(2) 142(1) of the Act by the Ld. AO from time to time. During the assessment proceedings, the assessee has also submitted revised computation of total income of Rs. 5,71,00,430/- by offering interest income capital gains to tax pursuant to decision of Hon ble Supreme Court in Bangalore Club Vs CIT reported in 350 ITR 509 (SC). 3.2. The ld. AO after due application of mind has added catering income by treating the said receipt being not covered under principle of mutuality. Thus, the ld. AO has accepted the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e. In response, the assessee has filed necessary details vide letters and wherein it was categorically explained that the revenue from cricket activity (namely Test matches and IPL matches have been duly offered to tax. However, the Ld. PCIT rejected the contention of the assessee and vide order dated 30.03.2015 set aside the assessment order holding that the same was erroneous and prejudicial to the interest of the revenue on the following reasonings: (i) The Ld. PCIT was of the opinion that the Ld. AO has simply accepted the claim of principle of mutuality which is contrary to the nature of activity undertaken by the assessee as in his view that the operation income and investment of the assessee are so large as to project existence of commercial motives in contrast to mutuality. (ii) The identity between the contributors and participators in the facts of the case of the assessee is missing as variety of members contributes to the fund of the assessee but only few members are entitled to surplus. (iii) The assessee exist primarily for the promotion of cricket and running the activities of club is secondary. (iv) The conduct and manner in which the international cricke ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee is a mutual association and the amounts received by it from its members for sale of tickets to a cricket match do not have the character of income. It was submitted by the ld. AR as a statement from the Bar, that against this order of tribunal, no appeal has been preferred by the department before the Hon ble Bombay High Court. In our considered opinion, this judgement of tribunal assumes importance to the impugned issue, in view of the fact that in the said judgement, the tribunal had held that the assessee is a mutual association in the context of sale of tickets to members for the Test Match between England and India and the ld. PCIT is seeking to revive the same issue in the section 263 proceedings denying exemption from principles of mutuality on the ground that the assessee sold tickets to its members for an International Cricket Match and IPL Match. This is evident from para 6.3. of the order of ld. PCIT. 4.1. We find that the ld. AR before us submitted that the assessee was a party before the Hon'ble Supreme Court in CIT vs. Bankipur Club Ltd reported in 226 ITR 97 (SC). The facts of the assessee's case relating to the Asst Years 1977-78 and 1978-79 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT has revived the same issues and denied exemption on the ground that the assessee has temporary members, the surplus may not be distributed equally on winding-up and there are taxable transactions with non-members. 4.2. In the Asst Year 2004-05, the ld. AO had reopened the assessment on the ground that certain receipts by the assessee from its members were not entitled to the benefit of mutuality. However, after considering the submissions, the ld. AO framed the assessment on 31.12.2009 categorically accepting that the amounts received from members was not taxable on the principles of mutuality. 4.3. In the Asst Year 2005-06, the Ld. CIT(A) allowed the appeal of the assessee with the following significant observations :- 4.8. ..The assessee club is a very old organisation which is incorporated for the benefit of its members. The issue of principle of mutuality has been considered and upheld in the appellant's own case in the earlier years and there is no scope for any fresh debate. In addition to this, the AO has not found any facts to suggest that the club does not run under the principles of mutuality. He has assessed the receipts only on the ground that in abse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... correct in upholding the order of CIT(A) in deleting the addition of Rs 9,20,825/- made on account of club share income of assessee from caterer, on the ground that the same was exempt under principle of mutuality? The Hon ble Bombay High Court disposed of this question by observing as under:- 5. Last surviving question pertains to an addition of Rs 9.20 lakhs made by the Assessing Officer on the ground that the said sum was received by the assessee from the caterer whose services the assessee-club has availed to provide catering services to the club members. The Commissioner of Income Tax, however, while deleting such disallowance came to the conclusion that the club had collected money from the members for food and refreshment out of which a sum of Rs 9.20 lakhs was retained while releasing the payment in favour of the caterer. This was, thus, a sum collected from the members on the principle of mutuality. This amount was, therefore, not taxed. 6. It may be seen that while making payment to the caterer from the amount collected from the members, the club had retained a small portion to meet with its administrative expenses. We find no error in the view of the Commissione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e cause of action for each assessment year is distinct. The Courts will generally adopt an earlier pronouncement of the law or a conclusion of fact unless there is a new ground urged or a material change in the factual position. The reason why Courts have held parties to the opinion expressed in a decision in one assessment year to the same opinion in a subsequent year is not because of any principle of res judicata but because of the theory of precedent or the precedential value of the earlier pronouncement. Where facts and law in a subsequent assessment year are the same, no authority whether quasi-judicial or judicial can generally be permitted to take a different view. This mandate is subject only to the usual gateways of distinguishing the earlier decision or where the earlier decision is per incuriam. However, these are fetters only on a coordinate Bench which, failing the possibility of availing of either of these gateways, may yet differ with the view expressed and refer the matter to a Bench of superior strength or in some cases to a Bench of superior jurisdiction . [Emphasis supplied] c) Decision of Hon ble Delhi High Court in the case of CIT vs Escorts Ltd reported ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rnaments. In addition, it provides avenue for sports and games as well as facilities for recreation and entertainment for the Members. It maintains Tennis Courts in pursuance of another outdoor activity. The indoor games for which provision is made include Billiards, Table Tennis, Badminton and Squash. It also maintains a swimming pool. The Club has also provision for residence of members, for which purpose it has constructed 48 residential flats and 40 residential rooms, some of which are air- conditioned. Persons occupying these residential flats and rooms are charged at different rates according to the accommodation provided. There is also a Catering Department which provides food and refreshments for the members coming to the Club as well as those residing in the residential portion, and it also makes arrangements for dinners and parties on special occasions at the request of Members. The affairs of the Club are managed by an Executive Committee and various honorary office bearers. 3. As is usual in most Clubs, the membership is varied. There are life members, ordinary members, temporary members, service members and honorary members. Guests, both local and from outstation, a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as Gymkhana Club Employees' Union v. The Management of the Gymkhana Club(1), this Court should hold that the Club is not an industry. 4. Our task for the decision of this case has been simplified, because this Court, in the case of Madras Gymkhana Club(1), has clearly laid down the principles of law which have to be applied in determining when a Club can be held to be an industry. In that case, the entire previous case-law relating to various institutions was fully discussed. After that discussion, the conclusion of the Court was mainly expressed in the following words :-- The principles so far settled come to this. Every human activity in which enters the relationship of employers and employees, is not necessarily creative of an industry. Personal services rendered by domestic and other servants, administrative services of public officials, service in aid of occupations of professional men, such as doctors and lawyers, etc., employment of teachers and so on may result in relationship in which there are employers on the one side and employees on the other, but they must be excluded because they do not come within the denotation of the term industry . Primarily, therefor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ustry. These are the main principles which have to be kept in view in arriving at the decision whether the Club is an industry or not. 5. The principal argument of Mr. Vimadalal, learned counsel for the Club, was that there is a basic and overall similarity between the Club and the Madras Gymkhana Club, so that the decision of this Court in the case of the latter is fully applicable. It was pointed out that both Clubs are Members' Clubs and not proprietary Clubs. The primary objects of both the Clubs are to provide venues for sports and games and facilities for recreation and entertainment of Members and guests introduced by Members. Both Clubs are sports, social and recreational Clubs. Grounds are maintained by both Clubs for promotion of sports, with the slight difference that, while in the Madras Gymkhana Club the outdoor games promoted are Golf, Rugby, Foot-ball and Tennis, in the Club the two outdoor games on which the Club concentrates are Cricket and Tennis. Both have indoor games, while the Club in addition, maintains a Swimming Pool for the Members. Both Clubs run tournaments and matches for the benefit of members and open tournaments are held for exhibition to memb ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng visits of foreign teams and of visits of Indian teams to foreign countries in cl. (c), organising and promoting or assisting in the organisation or promotion of Provincial Cricket Associations and Inter-Provincial Tournaments in el. (d), buying, repairing, making, supplying, selling and dealing in all kinds of apparatus and appliances and all kinds off provisions, liquid and solid, required by persons frequenting the Club buildings or the cricket grounds or other premises of the Club in clause (g) and paying all or any part of the experts of any cricket match, tour or tournament, or any other sporting events or match or competition in any other form of game, athletics, or sport and any kind of entertainment, exhibition or display in clause (1 ), are not activities which should form part of a social and recreational Club. The argument ignores the fact that the Club is not only a social and recreational Club, but is a Club of Members organised with one of 'the primary objects of encouraging and promoting sports and games. The activity of promotion of sports and games by a set of people combining together to form a Club cannot be said to be an undertaking in the nature of a tra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... with compulsory boarding require co-operation between capital and labour. In examining this aspect, the Tribunal a ears to have fallen into an error in ignoring the circumstance that the income, which earned by the Club from investment on these immovable properties, cannot be held to be income that accrues to it with the aid and co-operation of the employees. The material on the record shows that, out of 397 employees, only 14 attend the three immovable properties consisting of the Club Chambers, North Stand Building, and Stadium House. It may be presumed that the buildings which are let out for use as shops and offices are part of the Stadium House; but there 'is nothing to show how many of these employees are employed in the work connected with these buildings. In fact, on the face of it, it would appear that, once those buildings have been let out to other persons for use as shops and offices, there would be no need at all for the Club to maintain an employee-staff in order to look after those buildings, so that it is likely that all the 14 employees, who, it is admitted, attend the immovable properties, must be doing so primarily in order to look after the Club building ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ber, provision of facilities of the Club for him partakes of the same nature as for other members and, consequently, such an activity by the Club continues to remain a part of it as a self-serving institution. It is quite wrong to equate it with the activity of a Hotel. It may also be mentioned that there is definite evidence given on behalf of the Club that the charges for the residential accommodation with catering are much lower in the Club than the charges made for similar facility in any decent Hotel in Bombay where comparable accommodation may be provided. This further clarifies the position that this is a facility provided by the Club at concessional rates exclusively for its Members. 10. We may at this stage also deal with the argument advanced on behalf of the Union in respect of the nature of catering activities of the Club. So far as the catering in the Refreshment Room maintained by the Club and for persons occupying the residential accommodation is concerned, it is confined to Members of the Club only. No outsider is allowed to take advantage of this facility. In fact, the bye-laws of the Club clearly lay down that, even if a guest is introduced by a Member, the gue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Union, an example was cited of an occasion when a function was held to celebrate the Golden Jubilee of the Bank of India and catering was provided for a large number of guests at the Club. In answer to interrogatories served by the workmen, it was admitted by the Secretary of the Club that there was also another function of celebration of the silver Jubilee of the Bombay Mercantile Co-operative Bank Ltd. when also catering was provided by the Club. It was stated on behalf of the workmen that, on these occasions, the invitations were issued not in the name of any Member of the Club, but in the name of the organisations which held the functions. The affidavit filed by the Secretary of the Club, however, shows that in these two cases or in other cases where parties or functions are held in the Club, the Club never enters into any contract with any outsider. The Club, in fact. provides the catering at the instance of a Member of the Club. It appears that some Members of the Club are connected with organisations like the Bank of India or the Bombay Mercantile Co-operative Bank Ltd., and they adopted 'the course of arranging the function with the Club in their capacity as Members. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wo functions held for celebration of Jubilees of the two Banks. It is quite likely that a large number of these parties at which the attendance was 800 or more may have been given personally by Members of the Club on their own account in order to entertain people for their own personal celebrations on occasions such as marriages of sons or daughters. In fact, the evidence given before the Tribunal was limited to only two specific instances where functions were held for celebration by organisations and. not by Members of the Club themselves. In the absence of any material showing that a large number of parties were of that nature, no inference could follow that this was a systematic arrangement by which the Club was attempting to make profit; and the Tribunal, in phasing its decision on this ground, was not correct. The few instances cited do not, in our opinion, indicate that the Club is carrying on this activity in such a manner that it must be held to be an industry. 13. Very great reliance was placed in support of the decision of the Tribunal on the fact that the Club has erected a Stadium at the Cricket field where matches are held and makes an income of about Rs. 2 lakhs on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terest in the public in general in the game of cricket. It was obviously with this object that the Stadium was constructed. Its use by spectators interested in the matches or by members of other organisations interested in the game of cricket is purely for the purpose of encouraging and promoting the game of cricket in pursuance of that primary object of forming the Club. It is true that, in carrying on this object of the Club, the Club has been charging the spectators by selling tickets to them and also charging organisations to whom seats are specially allotted. So far as seats allotted to those organisations are concerned, we are inclined to accept the argument advanced 'by Mr. Vimedalal that this arrangement, instead of enuring to the benefit of the Club, in fact is to its disadvantage. We have already indicated that at least in one case of the Catholic Gymkhana Ltd., the charge that is made from the Gymkhana is at a very low rate of Rs. 5 or Rs. 4 per seat. On the face of it, if the Club was intending to make profits, it need not have given those seats to the Gymkhana and could have sold the seats to outsiders at much higher rates. The very fact that such agreements have b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed as a Limited Company under the Indian Companies Act. It was urged that the effect of this incorporation in law was that the Club became an entity separate and distinct from its Members, so that, in providing catering facilities, the Club, as a separate legal entity, was entering into transactions with the Members who were distinct from the Club itself. In our opinion, the Tribunal was right in holding that the circumstance of incorporation of the Club as a Limited Company is not of importance. It is true that, for purposes of contract law and for purposes of suing or being sued, the fact of incorporation makes the Club a separate legal entity; but, in deciding whether the Club is an industry or not, we cannot base our decision on such legal technicalities. What we have to see is the nature of the activity in fact and in substance. Though the Club is incorporated as a Company, it is not like an ordinary Company constituted for the purpose of carrying on business. There are no share-holders. No dividends are ever declared and no distribution of profits takes place. Admission to the Club is by payment of admission fee and not by purchase of shares. Even this admission is subject to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the order passed u/s 263 of the Act for A.Y. 2010-11 8. We further find that the main basis of revision proceedings u/s 263 of the Act for A.Y. 2010-11 was the Enhancement Order of A.Y. 2009-10 passed by the Ld. CIT(A). Against the said enhancement order, the assessee company had preferred an appeal before this Tribunal. With regard to the ground relating to enhancement of assessed income by ld. CIT(A) by denying the benefit of mutuality, the Tribunal in ITA No. 6937/Mum/2014 dated 4.10.2017 had set aside the matter back to the office of ld. CIT(A) for fresh adjudication after giving opportunity of being heard to the assessee. 8.1. It is pertinent to note that the ld. CIT(A) vide his order dated 29.03.2019 in the giving effect proceedings, has withdrawn the enhancement notice dated 22.08.2014 by giving the following findings: 5.2. With reference to the above said issues pointed out in the notice of enhancement, my observations are as under: i) I find that the appellant has rightly pointed out that the decisions regarding computation of income on commercial basis like Surat City Gymkhana vs DCIT (supra), ignoring the provisions of section 14 are all in respect of cas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ected to assess the total income, in light of the assessment order passed on 21.12.2011 as modified/amended in light of the directions of the ITAT Mumbai vide order dated 04.10.2017. 5.4. Grounds 7 (raised before the ITAT) consisting of ground nos 7.1 to 7.3 are alternative grounds to ground no. 6 (on the issue of enhancement). Since, the enhancement notice has been withdrawn, the other grounds regarding claim of deductions, becomes infructuous and are accordingly, not adjudicated 5.5. The set aside issues are decided and disposed off on the above terms. 8.1.1. Thus, the ld. CIT(A) has given a finding that (i) the assessee club is eligible for exemption under the Principle of Mutuality which shall not be affected by dealings with non-members, (ii) income of the assessee club is to be determined according to the provisions of section 14 of the Act. (iii) Alternatively, a finding is also given if the principle of mutuality is denied to the assessee, then its total income will work to a negative as against positive assessed income. The above findings are equally applicable for the year under consideration as there is no change in facts of the case. Infact the assessee had al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... utual association or not ; with regard to taxability of Catering Revenue ; allowability of expenses incurred for holding cricket matches together with its revenue ; taxability of interest income and short term capital gains u/s 111A of the Act , we find that the ld. AO had issued notice u/s 142(1) of the Act dated 8.11.2012 in the scrutiny assessment proceedings, wherein vide Point (ii), Point (vii) enclosed in Page 111 of Paper Book ; vide Question No. (iii) in Page 116 of the Paper Book ; vide Specific Query in Question No. (vi) in Page 117 of the Paper Book filed before us on the impugned issue. We find that the replies to the said questions were given by the assessee vide various letters dated 3.5.2012, 26.12.2012 and 4.3.2013. The relevant details of the said replies are enclosed in Page 119 of the Paper Book vide Point No. 5 Page 122 of the Paper Book and Paras 3 4 Pages 123 to 125 of the Paper Book ; Para 8 to 10 in Pages 126 to 128 of the Paper Book; Paras 1 to 5 Pages 129 to 130 of the Paper Book. These details were thoroughly examined and verified by the ld. AO in the scrutiny assessment proceedings itself. Infact the ld. AO had even taken a stand in paragraphs 2, 5 and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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