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Issues involved:
1. Dispute over deletion of addition of professional receipts in reassessment for the assessment year 1985-86. 2. Dispute over deletion of addition of unexplained investment/expenditure for the assessment year 1985-86. 3. Dispute over allowing interest under section 214 of the Income Tax Act for the assessment year 1988-89. Issue 1: Dispute over deletion of addition of professional receipts in reassessment for the assessment year 1985-86: The Revenue appealed against the deletion of an addition of Rs. 13,000 made by the Assessing Officer (AO) on account of separate professional receipts in reassessment. The Revenue argued that the addition was justified as the professional income of the assessee, a renowned advocate, should have been higher to cover household expenses. The authorized representative of the assessee contended that the addition was made without proper evidence or basis. The Tribunal found that there was no convincing evidence to support the estimate of professional income or higher household expenses. Relying on legal precedents and lack of supporting evidence, the Tribunal upheld the deletion of the addition by the Commissioner of Income Tax (Appeals) and dismissed the Revenue's appeal. Issue 2: Dispute over deletion of addition of unexplained investment/expenditure for the assessment year 1985-86: The Revenue disputed the deletion of an addition of Rs. 20,890 on account of unexplained investment/expenditure. The Revenue relied on the AO's order, while the authorized representative of the assessee argued that no new evidence was presented post the original assessment under section 143(3). The Tribunal noted that the AO failed to provide specific instances of unexplained expenditure/investment to justify the addition. After considering the explanations and lack of fresh evidence, the Tribunal upheld the deletion of the addition by the Commissioner of Income Tax (Appeals) and dismissed the Revenue's appeal. Issue 3: Dispute over allowing interest under section 214 of the Income Tax Act for the assessment year 1988-89: The Revenue challenged the direction of the Commissioner of Income Tax (Appeals) to allow interest under section 214 to the assessee. The Revenue argued that the interest was not warranted as the assessee did not furnish an estimate/statement of advance tax. The authorized representative of the assessee contended that the assessee had filed the estimate of advance tax and paid it before the specified date. The Tribunal found that the direction to allow interest under section 214 was justified based on the legal provisions and factual circumstances. The Tribunal declined to interfere with the decision, upholding the direction to allow interest under section 214. Additionally, a related ground of dispute regarding the interpretation of the issue was also dismissed by the Tribunal. In conclusion, the Appellate Tribunal ITAT JODHPUR addressed multiple issues related to income tax assessments in the mentioned judgment. The Tribunal carefully analyzed the arguments presented by both the Revenue and the assessee, considered relevant legal precedents, and made decisions based on the evidence and legal provisions. The Tribunal upheld the deletion of additions in the assessment for the year 1985-86 and allowed interest under section 214 for the assessment year 1988-89, dismissing the appeals filed by the Revenue in both instances.
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