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Issues:
1. Claim for deduction on account of purchase tax liability on accrual basis. 2. Disallowance of enhanced deduction claim before appellate authority. 3. Maintainability of revision petition under section 264 of the Income-tax Act. Analysis: 1. The petitioner, a partnership-firm engaged in manufacturing poultry feed, made a provision for purchase tax liability in the books of account for the assessment year 1976-77. The Assessing Officer disallowed the deduction claimed at Rs. 20,000. The petitioner contended that since the liability on account of purchase tax accrued at the event of purchase, it should be allowed as a deduction on accrual basis. The Appellate Assistant Commissioner accepted the plea and allowed the deduction. However, the Commissioner of Income-tax dismissed the revision petition, stating that the claim had already been accepted by the Appellate Assistant Commissioner. The petitioner argued that the liability to pay tax had accrued in the previous year, justifying the enhanced deduction claim. 2. The petitioner's counsel argued that the additional demand for purchase tax was upheld through appellate proceedings. The Supreme Court precedent established that liability to pay tax arises at the event of sale or purchase, allowing deduction on accrual basis. The petitioner initially claimed Rs. 20,000 deduction, which was accepted by the Appellate Assistant Commissioner. The claim for an enhanced deduction was not raised during the appeal process. The Commissioner of Income-tax rejected the revision petition on similar grounds, emphasizing that the petitioner should have filed an appeal before the Income-tax Appellate Tribunal for the enhanced deduction claim. 3. The judgment highlighted that the petitioner's claim for an enhanced deduction was not raised at the appropriate stages of assessment and appeal. The appellate authority can only grant relief to the extent unjustifiably declined by the lower authority. The petitioner's failure to raise the enhanced claim before the assessing authority or in the appeal process led to the dismissal of the petition. The judgment concluded that the petitioner had no case against the assessment made by the Income-tax Officer, as the appeal effect had been duly considered. The appropriate forum for claiming a higher deduction was outlined to be the Assessing Officer, and the failure to do so precluded the petitioner from seeking relief through appeal or revision. In conclusion, the petition was found to be without substance and was dismissed, with no order as to costs.
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