1983 (1) TMI 130

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..... 69 days. However, the learned counsel for the assessee submitted that the firm, which is constituted of two partners, namely, Shri Gursharan Singh and Smt. Daljit Kaur, was prevented by reasonable and sufficient cause from filing the appeal within time. In this regard he submitted that the due date of filing the appeal was 4th August 1982. However, both the partners had gone abroad. Shri Gursharan .....

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..... ssessee had debited Rs. 17,811 under the buildings account. The ITO on the paper on which this profit and loss account is filed made the following jottings but took the total income of the assessee at Rs. 15,360 obviously rounding off the figure of Rs. 15,357.91 to the nearest multiple of ten: 11,424.44 343.47 3,600.00 15,367.91 17,811.50 33,179.41 This expenditure of Rs. 17,811 had .....

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..... advise the ITO as to what he should consider about the nature of a particular expense. It was the sphere of the ITO alone, as pointed out by the Hon'ble Supreme Court in the India & Eastern Newspaper Society Ltd. vs. CIT (1979) 12 CTR (SC) 190 : (1979) 119 ITR 996 (SC). The AAC, however, held that the action of the ITO was justified and confirmed the reopening of the assessment. However, insofar .....

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