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Showing 61 to 80 of 1262 Records
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2015 (6) TMI 1209 - ITAT KOLKATA
Revision u/s. 263 - revision ordered for short deduction of TDS - HELD THAT:- This is merely a case of short deduction of TDS. Admittedly, the assessee has made labour payment or debited labour payment in the P&L Account and deducted TDS i.e. @ 1%. At best this can be a case for short deduction.
Short deduction no disallowance can be made by invoking the provisions of section 40(a)(ia). This view of ours is fortified by the decision in the case of CIT Vs. M/s. S. K. Tekriwal [2012 (12) TMI 873 - CALCUTTA HIGH COURT] wherein held Sec 40(a)(ia) can be invoked only when the two conditions, namely, that tax is deductible at source and such tax has not been deducted is satisfied. Where tax is deducted by the assessee under a wrong provisions of TDS and there is a shortfall, u/s 40(a)(ia) disallowance cannot be made.
As the issue of short deduction is settled revision proceedings initiated by CIT u/s. 263 are invalid and hence, quashed. - Appeal of assessee is allowed.
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2015 (6) TMI 1208 - ITAT AHMEDABAD
Non prosecution of appeal by assessee - HELD THAT:- As on the date of hearing i.e. 29.06.2015 none appeared on behalf of assessee nor filed any adjournment petition. This shows that assessee is not interested in prosecuting this Appeal.
It is clear that the assessee is not interested in prosecuting these appeals, and accordingly, following the decision of the Multiplan (India) (P) Ltd., [1991 (5) TMI 120 - ITAT DELHI-D] we dismiss this appeal filed by assessee for want of prosecution.
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2015 (6) TMI 1207 - ITAT MUMBAI
Interest expenditure incurred allowable - Addition u/s 36(1)(iii) or u/s 14A - HELD THAT:- Assessee company is engaged in the business of finance and investment in equity shares. The borrowed capital was used for acquiring the equity shares of the subsidiary to have controlling interest. The proposition of law laid down in the case of “Phil Corpn. Ltd.” [2011 (6) TMI 912 - BOMBAY HIGH COURT] is squarely applicable to the case of the assessee.
In the case of “Eicher Goodearth Ltd. vs. CIT” [2015 (5) TMI 685 - DELHI HIGH COURT] has held that if the expenditure is incurred for the purpose of promotion of business more specifically to retain control or as part of the strategic investment of the assessee company, such expenses by way of interest out go would have to be treated as allowable under section 36(1)(iii) . The above decision of the Hon’ble Delhi High Court is also squarely applicable to the facts of the case of the assessee.
Since the interest expenditure incurred by the assessee is allowable under section 36(1)(iii) as business expenses, there is no question of disallowance of the same u/s 14A of the Act on account of investments made in relation to earning of exempt income. The facts on the file clearly reveal that the investment in the shares of the subsidiary company was not made for the purpose of earning of any exempt income rather it was made for gaining controlling interest over the subsidiary which as per the law laid down in the case of “CIT, Panaji, Goa vs. Phil Corpn. Ltd.” [2011 (6) TMI 912 - BOMBAY HIGH COURT] and “Eicher Goodearth Ltd. vs. CIT” [2015 (5) TMI 685 - DELHI HIGH COURT] is held to be for the purpose of promotion of the business of the assessee.
Even it is also an admitted fact that the assessee during the year had not earned any exempt income. The AO had made the disallowance under section 14A relying upon the decision of the special bench of the Tribunal in the case of “Chem. Investments vs. ITO” [2009 (8) TMI 126 - ITAT DELHI-B]. However, we find that the said special bench decision of the Tribunal has been overruled by the Hon’ble Delhi High Court in the case of “Chem. Investments [2015 (9) TMI 238 - DELHI HIGH COURT] wherein the Hon’ble Delhi High Court has held that the section 14A will not apply if no exempt income is received or receivable during the relevant previous year.
Even otherwise, no disallowance is warranted under section 14A of the Act also, in the case of the assessee.
Neither any interest disallowance is warranted in this case under section 36(1)(iii) of the Act nor under section 14A of the Act. Appeal of the assessee is hereby allowed.
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2015 (6) TMI 1206 - ITAT MUMBAI
Deduction u/s 80IA(4)(i) - Whether widening of existing roads constitute creation of new infrastructure facility for the purpose of section 80IA(4) - HELD THAT:- Section 80IA mainly speaks of development of infrastructure facility; whether widening of roads would amount to development of infrastructure facility has been clarified by the CBDT and the same is binding on the Revenue. In the light of the circular issued by CBDT and also the decision in the case of Rohan & Rajdeep Infrastructure [2013 (4) TMI 758 - ITAT PUNE] wherein circular No. 4/2010 was applied by the Tribunal to hold that widening of roads would amount to new infrastructure facility falling within the purview of section 80IA of the Act - the expression development of infrastructure facility includes widening of roads. Under these circumstances we do not find any infirmity in the order passed by the CIT(A). Appeal filed by the Revenue is dismissed.
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2015 (6) TMI 1205 - KARNATAKA HIGH COURT
TDS u/s 195 - remittances towards the cost of the software products imported from foreign suppliers - addition u/s 40(a)(ia) - Whether it is not royalty? - HELD THAT:- In view of the judgment of this Court in Samsung Electronics Pvt Ltd [2011 (10) TMI 195 - KARNATAKA HIGH COURT]as already the earlier order of the Tribunal is set aside by this Court, the impugned order passed, which is running counter to the said judgment, requires to be set aside and therefore, the appeal is allowed and the substantial question of law is answered in favour of the Revenue and against the assessee.
However, in the event the assessee succeeds before the Apex Court, it is clear that this order also cannot come into effect. The assessing authority shall therefore, pass an order under S.260(1A) of the Act, based on the outcome of the assessee’s appeal before the Apex Court. If the assessee loses his battle before the Apex Court, then before giving effect to this order, the assessing authority shall consider the application of Art.24(4) of the DTAA between India and the Netherlands.
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2015 (6) TMI 1204 - ITAT CHENNAI
Allowability of provision for gratuity debited to the Profit & Loss Account - applicability of provisions of section 43B and 40A(7) - HELD THAT:- We find that the issue adjudicated by the Tribunal for the assessment year 2007-08 [2014 (12) TMI 1356 - ITAT CHENNAI] is identical in principle to the one raised in this appeal. It is the decision of the Tribunal that provisions of section 40A(7) take precedence over the provisions of section 43B of the Act. Therefore, respectfully following the said decision of the Tribunal, we find that the order of the CIT(A) is fair and reasonable and it does not call for any interference. - Decided against revenue.
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2015 (6) TMI 1203 - ITAT MUMBAI
Rectification of mistake u/s 254 - scope and ambit of application u/s 254(2) - Wrong or erroneous recording and consideration of facts, Non-adjudication/Non-consideration of claim/ argument / submission of the assessee and All case laws cited and relied by assessee were not considered and discussed by the Tribunal in its order - HELD THAT:- It is not the case that the main appeal of the assessees were disposed off without granting opportunity to the assessee, rather the order has been passed by the Tribunal by objectively considering the facts and material available on record and that too after hearing both the parties. Through these miscellaneous applications, in our humble opinion, the assessee is trying to get the order reviewed, which is not permissible u/s 254(2) of the Act. The expression ‘mistake apparent on record’ , it is well settled, means a mistake either clerical, grammatical, arithmetical or of like nature, which can be detected without there being any necessity to reargue the matter or to reappraise the facts as appearing from the record can only be rectified. Likewise, the possibility of forming of a different opinion then the one expressed in the order passed u/s 254(1) cannot be treated as ground for entertaining the application u/s 254(2) of the Act.
We find that under the facts and circumstances available on record, possibly, the order was passed by the Tribunal after considering the arguments from both sides. Once the possible view has been taken, on the basis of material available on record, it cannot be said there is apparent mistake in the order which can be rectified u/s 254(2). See ANAMIKA BUILDERS PVT. LTD. [2001 (5) TMI 39 - CALCUTTA HIGH COURT] and POPULAR ENGINEERING CO. [2001 (1) TMI 76 - PUNJAB AND HARYANA HIGH COURT]
Totality of facts clearly indicates that there is no mistake apparent from record in the order of the Tribunal. Even otherwise, the order was passed by the Tribunal after considering the arguments advanced from both sides with high sense of responsibility and as mentioned earlier through these applications, the assessee is merely trying to get the orders reviewed/recalled, which is not permissible u/s 254(2) - Miscellaneous Applications, filed by the assessees, are dismissed.
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2015 (6) TMI 1202 - MADRAS HIGH COURT
Compounding of offence - release of detained goods alongwith vehicle - case of petitioner is that the second respondent has no jurisdiction or authority, as he is not the assessing authority to compound the offence on receiving the amount - Circular No.33/2014 Q4/7752/2014 dated 17.7.2014 - HELD THAT:- Mere reading of Rule 15(1) & 15(4) of the TNVAT Rules says that the officers of Commercial Taxes Department not below the rank of Deputy Commercial Tax Officer shall be the officer prescribed for the purposes of Sections 65, 66, 67, 68 and 69. Although this may be so, the Circular No.33/2014 Q4/7752/2014 dated 17.7.2014 issued by the Principal Secretary/Commissioner of Commercial Taxes, Chennai clearly shows that the movement of goods, if accompanied with a valid invoice, would satisfy the provisions of Section 68 of the TNVAT Act, hence, there is no offence falling under Section 71(5)(a) of the TNVAT Act. Further, when Rule 15(1) totally excludes the operation of Section 72(1)(a) of the TNVAT Act and also for the reason that the movement of goods were accompanied with valid invoices as per Section 68 of the TNVAT Act, the impugned goods detention notices issued by the second respondent in both the writ petitions are liable to be set aside.
The impugned orders are set aside and the respondents are directed to release the goods forthwith to the petitioners on production of a copy of this order - Petition allowed.
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2015 (6) TMI 1201 - MADRAS HIGH COURT
Reversal of ITC - the registration certificates of the sellers have been cancelled - TNVAT Act - HELD THAT:- When the purchases of goods from the these dealers were duly entered and reflected in the accounts and monthly returns filed, giving details of purchasers including the registration particulars, commodity code, value, rate of tax, amount of VAT and category of goods in the Annexure I of the said returns, the respondent, in the impugned orders, have not mentioned anywhere that the purchases of goods from the above dealers are doubtful or incorrect. That apart, the foundation upon which the respondent has passed the impugned orders clearly shows the reason that the certificates of registration of the dealers have been cancelled, reversal of ITC has to be effected against the petitioner.
The said approach adopted by the Assessing Officer is contrary to the settled legal position - the impugned orders are liable to be set aside and accordingly, the same are set aside.
Petition allowed.
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2015 (6) TMI 1200 - ITAT MUMBAI
Disallowance towards Employee Stock Option Plan (ESOP) expenses - Revenue or capital expenditure - HELD THAT:- An identical issue was considered by the Tribunal Special Bench Bangalore in the case of Biocon [2013 (8) TMI 629 - ITAT BANGALORE] has held that ESOP expenses is an allowable deduction u/s. 37(1). The same view was followed by ITAT Pune Bench in the case of Sandvik Asia [2014 (12) TMI 1236 - ITAT PUNE] . Respectfully following the decision of the Co ordinate Benches, we set aside the order of the Ld. CIT(A) and direct the AO to allow the ESOP expenses as revenue expenditure. - Appeal filed by the assessee is allowed.
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2015 (6) TMI 1199 - ITAT PANAJI
Levy of penalty u/s.271(1)(c) OR 271AAA - search conducted u/s. 132 - in statement made u/s.132(4) assessee offered total additional undisclosed income - HELD THAT:- The entire penalty order refers to levy of penalty for the concealment of income because the income was offered only after the search and since income was not offered in the original return of income, penalty was leviable.
In the anxiety of levying the penalty u/s. 271(1)(c) of the Act, the Officer simply ignored the provisions of sec. 271AAA of the Act which have been introduced for the searches conducted on or after 01/06/2007. The Officer failed to appreciate that the assessee has fulfilled all the conditions mandatory to get immunity from the levy of penalty.
AO did not consider the fact that in his statement made u/s. 132(4) of the Act, the assessee has offered additional income for tax. The assessee has paid taxes on the said undisclosed income offered and the assessee has explained the source from which the said income has been earned. We, therefore, do not find any merit in the grievance of the Revenue. We, therefore decline to interfere with the findings of the Ld. CIT(A). - Decided against revenue
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2015 (6) TMI 1198 - ITAT HYDERABAD
Interest accrued on the special fund created - taxabilty at the hands of assessee as it is the income of REC - whether the accrued interest on investments made by assessee of the loan amount received from REC is taxable at the hands of assessee ? - HELD THAT:- DR has not brought any other material to our notice to indicate that facts of the impugned AYs are in any way different from the facts considered by the Tribunal while deciding the issue in favour of assessee. Further, the department’s contention that interest income has not been shown by REC cannot justify the addition at the hands of assessee. In the aforesaid view of the matter, following the decision of the coordinate bench in assessee’s own case for the preceding AYs, we uphold the order of ld. CIT(A) by dismissing the grounds raised by the department in all the appeals under consideration. - Decided against revenue
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2015 (6) TMI 1197 - ITAT AHMEDABAD
Rectification u/s 254 - disallowance u/s. 14A r.w.r. 8D - HELD THAT:- Hon’ble Gujarat High Court in Assessee’s own case is A.Y. 2006-07 while deciding the Special Civil Application has held that provisions of Rule 8D are applicable from A.Y. 2008-09 and is not retrospective. Considering the aforesaid fact, we are of the view that there is an apparent mistake in the order of Tribunal and therefore recall the order for a limited purpose to decide the issue with respect to disallowance u/s. 14A of the Act. The Registry is directed to fix the hearing the appeal in due course.
Disallowance u/s. 36(1)(iii) - HELD THAT:- It is also well settled/established law that the Tribunal is not bound to discuss each and every argument made at the time of hearing of the appeal and the conclusion arrived by the Tribunal may be an error of judgment but cannot be considered to be an error apparent on record rectifiable u/s. 254(2) of the Act.
The powers of the Tribunal u/s 254(2) is very limited and the Tribunal has limited jurisdiction of rectification in its order if an error is crept therein which is apparent from the face of the record. Reappreciation of the evidence placed before the Tribunal during the course of hearing is not permissible to re-adjudicate the issue afresh under the garb of rectification.
The power to review is not available to the Tribunal. If we accept this petition, then this may tantamount to review of an order of the Tribunal and the law is settled that we have no such power. Further, we also find support to our aforesaid view by the decision in the case of Perfetti Van Melle India (P) Ltd. vs. CIT [2007 (5) TMI 214 - DELHI HIGH COURT] wherein the Hon'ble High Court has concluded that Assessee cannot be allowed to reopen and reargue the whole matter in the garb of rectification under section 254(2). We are of the view that since the assessee has failed to point out any mistake apparent from record in the order, we are not inclined to recall the order of the Co-ordinate Bench in M.A. with respect to disallowance u/s. 36(1)(iii).
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2015 (6) TMI 1196 - ITAT LUCKNOW
TDS u/s 195 - non-deduction of TDS on payment of commission to Foreign Agent - place of business in India - CIT-A deleted the addition - HELD THAT:- Nothing has been brought on record by the Revenue in order to demolish the stand taken by the assessee and to establish that non-resident has ever rendered any technical services or consultancy or managerial services. Therefore, we are of the view that since the assessee has simply procured export orders through commission agent for which commission was paid, the assessee was not required to deduct tax at source on the commission paid to the foreign agent. Accordingly we confirm the order of the ld. CIT(A). - Decided in favour of assessee.
Disallowance on ad-hoc basis - as alleged non pointing out any specific defect in the accounts of the assessee - CIT-A deleted the same for the reason that the AO has made ad-hoc disallowance - HELD THAT:- During the course of hearing before us, similar is the position, as the Revenue could not point out any specific defect in the maintenance of accounts under different heads. No doubt the Assessing Officer can make disallowance if the assessee fails to produce the relevant evidence with respect to any particular expenditure, but the disallowance on ad-hoc basis is not permissible under the law. We, therefore, find no merit in these grounds of appeal - Decided in favour of assessee.
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2015 (6) TMI 1195 - ITAT CHANDIGARH
Characterization of income - Sales Tax subsidy receipt - revenue receipt or capital receipt - HELD THAT:- Unit of assessee was set up as per scheme formulated by Government of West Bengal and assessee has been allowed remission of sales tax for 12 years upto 100% of gross fixed capital investment/asset of the approved project. The incentive scheme was available for location of the unit. No incentive is available to units located in group ‘A’. The unit of assessee is located in group ‘B’ (Hooghly). The subsidy would help the growth of industry and not to supplement profit. Subsidy is determined with reference to the fixed capital investment/asset and not profit. No working capital is considered in the scheme. The ld. DR says that the subsidy is given for 12 years after production and as such it is revenue in nature. The arguments of ld. DR cannot be accepted in view of the above facts because the scheme is made to encourage the promotion of industries/setting up in the State of West Bengal. The incentives are provided to approved projects only. The purpose of giving subsidy is thus, to promote and set up industries in State of West Bengal.
The object/purpose of assistance under the subsidy scheme was to enable the assessee to set up new unit in State of West Bengal. Therefore, the receipt of the sales tax subsidy in the hands of assessee was capital in nature. The decisions relied on by ld. DR would not support the case of the revenue.
Considering case of Ponni Sugars & Chemicals Ltd. [2008 (9) TMI 14 - SUPREME COURT] and sales tax subsidy received by the assessee is capital receipt in nature and are not subjected to tax. The additions made by the AO on account of receipt of sales tax subsidy are accordingly deleted in all the assessment years in appeals. - Decided in favour of the assessee
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2015 (6) TMI 1194 - ITAT LUCKNOW
Addition u/s 69A - unexplained cash deposit - assessee has not given any documentary evidence to prove that cash deposit was his business turnover - CIT-A treating the cash deposit as business turnover of the assessee and applying G.P. rate of 13.8% - HELD THAT:- Clear finding has been given that on perusal of the entries reflected in the said bank account, it was revealed that the cash deposits and withdrawals were made regularly during the year and therefore the AO was not justified in making the addition of ₹ 15,68,500/-. CIT(A) has held that these receipts should be treated as turnover of the assessee from trading of cloth and has directed the Assessing Officer to make addition of profit from such turnover outside the books at gross profit rate of 13% of this turnover.
Cash deposit and withdrawal in the bank account was made regularly by the assessee during the year, it is very reasonable to say that the same was business turnover outside books and therefore, only gross profit addition is justified in the facts of the present case. Hence, we do not find any reason to interfere in the order of CIT(A) and therefore, we decline to interfere in the same. - Decided against revenue.
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2015 (6) TMI 1193 - ITAT MUMBAI
Rejection of Gross loss declared by the assessee - Rejection of Gross Profit declared by the assessee for its Nashik Unit and instead estimating the same at 10% of the sales - HELD THAT:- We notice that the assessee has failed to furnish convincing explanations with regard to the Gross loss declared by it. Even though, it is claimed that the Gross loss has occurred due to higher interest and depreciation, yet the CIT(A) noticed that the assessee has followed identical method of accounting in the immediately preceding year and declared profit. In the absence of any convincing reason for occurring of Gross loss, we are of the view that the Ld CIT(A) was justified in confirming the rejection of Gross loss declared by the assessee.
AO has estimated the Gross Profit @ 10% of the Gross sales. We notice that the AO has compared the Gross profit rate declared in the Pune unit and accordingly determined the rate of GP at 10%. The Ld CIT(A) also confirmed the same. Before us, though the assessee contended that it was not correct to estimate the Gross profit, yet no material was placed before us in order to compel us to disturb the estimate made by the AO. Accordingly, we confirm the order of Ld CIT(A) on this issue.
Computation of deduction u/s 10B in respect of Pune Unit and also the disallowance of loss declared by the Nashik Unit - HELD THAT:- In the instant case, has assessed the interest income under the head Income from other sources. On the contrary, the coordinate bench of Mumbai Tribunal, in the case of Larsen & Toubro Infotech Ltd [2012 (9) TMI 292 - ITAT MUMBAI] has expressed the view that the other income having no direct nexus with export of articles or things are not eligible for deduction u/s 10A of the Act. Accordingly, we confirm the reduction of profit eligible for deduction u/s 10B of the Act by the amount of interest income.
Rejection of deduction u/s 10-B of the Act relating to sub-contract works - AO the reduced the deduction u/s 10B of the Act to the extent of profit attributable to subcontracting works - HELD THAT:- A perusal of the provisions of sec. 10B(1) would show that the deduction prescribed therein is allowed to profits and gains as are derived by a hundred per cent export-oriented undertaking from export of articles or things or computer software i.e., section 10B nowhere provides anything about the mode of manufacture. Accordingly, we are of the view that the assessing officer was not right in holding that the assessee was not eligible for deduction u/s 10B of the Act in respect of profit attributable to sub-contract works. Accordingly, the Ld CIT(A) was not justified in confirming the same. Accordingly, we set aside the order of Ld CIT(A) as well as the AO on this issue.
Disallowance made u/s 14A - HELD THAT:- No requirement of making any disallowance out of interest expenditure. However, since the year under consideration is AY 2007-08 to which the provisions of Rule 8D are not applicable as per the decision of Godrej & Boyce manufacturing Co. [2010 (8) TMI 77 - BOMBAY HIGH COURT] , the disallowance u/s 14A is required to be computed in a reasonable manner. Accordingly, we set aside the order of Ld CIT(A) on this issue and restore the same to the file of the AO with the direction to examine this issue afresh and after hearing the assessee, take appropriate decision in accordance with the law.
Loss incurred in Nashik unit should not be set off against the Pune unit for computing deduction u/s 10B of the Act in respect of Pune unit - HELD THAT:- We notice that the co-ordinate bench of ITAT in the case of Larsen & Toubro Infotech Ltd [2012 (9) TMI 292 - ITAT MUMBAI] has taken the view that the deduction u/s 10B is allowable each undertaking wise and hence the loss incurred in one eligible unit should not be set off against the income from other eligible unit. We direct the AO to compute the deduction u/s 10B accordingly.
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2015 (6) TMI 1192 - ITAT AMRITSAR
Levy of fees under section 234E - intimation issued under section 200A - Held that:- We find that the issue in all these appeals is now squarely covered in favour of the assessee by the decision of ITAT Amritsar Bench in the case of Sibia Healthcare Private Limited vs. DCIT [2015 (6) TMI 437 - ITAT AMRITSAR] adjustment in respect of levy of fees under section 234E was indeed beyond the scope of permissible adjustments contemplated under section 200A. - Decided in favour of assessee
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2015 (6) TMI 1191 - ITAT AMRITSAR
Levy of fees u/s 234 E - intimations u/s 200A in respect of processing of TDS statements for the second and third quarter of the financial year 2013-14 - HELD THAT:- Appeal is covered in favour of the assessee by the decision of ITAT Amritsar Bench in the case of Sibia Healthcare Private Limited vs. DCIT [2015 (6) TMI 437 - ITAT AMRITSAR] wherein it has been held that prior to 01.06.2015, there was no enabling provision u/s 200A of the Act for raising a demand in respect of levy of fee u/s 234E - Decided in favor of assessee.
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2015 (6) TMI 1190 - ITAT DELHI
Condonation of delay - delay in filing the appeal by 315 days - Penalty u/s 271(1)(c) - assessee made a conditional surrender of ₹ 50,00,000/- and paid the tax on the said surrender subject to no penalty u/s 271(1)(c) - HELD THAT:- In the present case, it appears that the assessee made a conditional surrender of ₹ 50,00,000/- and paid the tax on the said surrender subject to no penalty u/s 271(1)(c). The assessee also furnished copy of order sheet dated 21.12.2009 which is placed at page no. 2 of the assessee's compilation, in the said order sheet also it is mentioned "subject to no penal action." Therefore, the assessee under bona fide believe that no penalty will be levied, surrendered ₹ 50 lacs and did not prefer an appeal. In our opinion, there was a reasonable cause in filing the appeal belated, therefore the delay is condoned and the appeal is admitted.
Reopening u/s 147 read with section 148 - unexplained entries in the bank account - HELD THAT:- AO initiated the proceedings u/s 147 of the Act on the basis that there were certain entries in the bank account of assessee for which there was no proper explanation. AO also noticed that the assessee produced fabricated copy of bank account along with books of accounts and as such formed the belief that the assessee's income had escaped assessment.
In the present case, the assessee although filed the objection against the initiation of re-assessment proceedings u/s 147 of the Act, however, withdrew those objection and surrendered a sum of ₹ 50,00,000/- subject to no penal action. In the instant case, when the assessee himself withdrew the objection filed against the initiation of re-assessment proceedings u/s 147 of the Act, surrendered a sum of ₹ 50,00,000/- and paid the tax thereon, in our opinion, the ld. CIT was fully justified in upholding the proceedings initiated by the AO u/s 147 of the Act and in confirming the addition of ₹ 50,00,000/-. We, therefore, don't see any merit in this appeal of the assessee
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