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Issues involved: Challenging the order of the Income Tax Appellate Tribunal, the revenue has proposed substantial questions of law regarding the deletion of certain additions made by the Assessing Officer u/s 40(a)(ia) of the Income Tax Act, as well as disallowance of Labour Charges Exp., Repairs & Maintenance expenses, and Diesel & Oil Expenses.
Regarding Labour Charges and Repairs & Maintenance expenses: The Tribunal did not entertain the revenue's question about the disallowance of these expenses, as it found that payments were made by cash with self-made vouchers presented, and no evidence suggested non-payment to the recipient. The Court deemed this issue not raising any substantial question of law. Regarding Diesel and Oil expenses: The Tribunal also did not entertain the question about disallowance of these expenses, as payments were made by verifiable cheques with no contradictory evidence provided by the revenue. The Court saw no reason to consider this question further, as it was solely based on facts. Regarding other questions (A) and (B): The Court noted that similar questions raised by the revenue in other tax appeals are already under consideration, with a notice of final hearing issued. Therefore, a notice for final disposal is required in this tax appeal to consider questions (A) and (B) as well, scheduled for return on 17th April, 2013.
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