9911796707
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Issues involved:
The judgment involves three Tax Appeals under Section 260A of the Income-tax Act, 1961 for the assessment years 1993-94, 1994-95, and 1998-99. The issues include excess consumption of raw materials, bogus loss on transactions with sister concerns, disallowance of depreciation, cash receipts on sale of waste, excess cutting, stitching, and printing charges, and suppression of profit through middlemen. Tax Appeal No.31 of 2009 (Assessment year 1993-94): (A) The Appellate Tribunal confirmed the deletion of the addition for excess consumption of raw materials based on evidence collected during a search. (B) The Tribunal also upheld the deletion of a &8377;33,38,680 addition for a bogus loss on transactions with sister concerns. The assessing officer's reliance on Section 40(A)(2)(b) was deemed incorrect as no excessive or unreasonable expenditure was proven. Tax Appeal No.30 of 2009 (Assessment year 1994-95): (A) The Tribunal confirmed the deletion of the addition for excess consumption of raw materials and disallowance of depreciation on assets installed in Woven Label Division. (B) The disallowance of &8377;35,42,089 for depreciation was unjustified as the machinery was installed during the relevant year. The addition based on cash receipts on sale of waste was deleted due to lack of evidence. Tax Appeal No.265 of 2009 (Assessment year 1998-99): (A) The Tribunal confirmed the deletion of the addition for excess consumption of raw materials and suppression of waste. (B) The addition of &8377;15,49,860 for suppression of waste was deleted as the assessing officer's conclusions were based on guesswork without substantial evidence. The Tribunal's decisions were based on detailed analysis of the facts and evidence presented. The assessing officer's reliance on incorrect figures and lack of concrete evidence led to the deletion of various additions. The Tribunal emphasized the importance of factual findings and lack of substantial questions of law in the appeals. Ultimately, all appeals were dismissed based on the findings of fact.
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