9911796707
TMI Blog1989 (11) TMI 96X X X X Extracts X X X X X X X X Extracts X X X X ..... on a deposit of Rs. 2 lakhs. It appears that no details thereof were given in the assessment order and the only observation made by the Inspecting Asstt. Commissioner (Assessment) was that " Interest on deposit of Rs.2 lakhs which is treated as income from undisclosed sources in assessment year 1982-83 ". 3. In appeal, the learned Commissioner of Income-tax (Appeals) observed that the assessee had surrendered an amount of Rs.5 lakhs as against the addition of Rs.7,53,000 made in the assessment year 1982-83 vide order dated 26-6-1986 of the IAC(A) and since the addition of Rs. 5 lakhs was made on account of unexplained deposits, the addition was confirmed. 4. After hearing the learned representatives on both the sides, it appears that th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to amount to expenses in the nature of entertainment : -------------------------------------------------------------------------------------------------------------------------------------------------- Date Particulars Others Foreign guests -------------------------------------------------------------------------------------------------------------------------------------------------- 31-10-1981Amount paid to M/s. Silhouette, Rs. 1,415.00 ---18-Lok Nayak Bhawan, Khan Market as per bills Nos. 981 1368 dt.29-10-1981for processing 7-11-1981Purchase of sweets on the oc- Rs. 8,820.00 ---casion of 'Diwali' vide cheque No. 749183 on State Bank of India (OB).12-11-1981Paid to M/s. Mehta Co. 59-M Rs. 317.00 ----Block,Connaught Place,Ne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y pointed out on behalf of the assessee by Shri Sapra, the disallowance could possibly relate to the following two items :-- -------------------------------------------------------------------------------------------------------------------------------------------------- Sl.No. Date Particulars Amount -------------------------------------------------------------------------------------------------------------------------------------------------- 1.30-6-1982Spent by Lamina Packers,Bombayon behalf of the assessee atBombayfor assessee's guests arranging lunch, breakfast, dinner, etc. Rs. 492 2.30-6-1982Amount transferred from travelling expenses account spent by the office staff for stationery and getting photostat copies, etc. durin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aid to the Export Inspection Agency, Delhi) but also in respect of the following two items of expenses as per the assessee's profit loss account, namely : (i) Fumigation charges paid to M/s.PestControl (I) Pvt. Ltd.and M/s. Mysodet Pvt. Ltd. Rs. 10,83,432.29 (ii) Paid to Geo Chem Lab. P. Ltd. for issue of quality certificate, supervision of loading etc. Rs. 76,869 The details of these items were also given at pages 49 to 51 of the assessee's paper book. However when the learned counsel for the assessee was asked as to how these two additional claims could be considered at the stage of the Appellate Tribunal, without any application of the assessee for raising additional grounds, when the IAC (Asst.) as well as the CIT (Appeals) had ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is clear from the letter dated10-3-1981of the Export Inspection Agency,Delhiaddressed to all exporters of Basmati rice (copy at page 38 of the assessee's paper book). Certain instructions were issued in pursuance of Rule 4 of the Export of ' Basmati ' Rice (Inspection) Rules, 1980 containing the scheme for compulsory quality control and pre-shipment inspection of Basmati rice. Detailed Executive Instructions were issued in that regard (copy of which appears on the assessee's paper book). They show that the samples of Basmati rice received in the laboratory were to be analysed for different characteristics mentioned in the specification and that a fee @ 25p. per 10 kg. or part thereof was to be paid by the exporter to the Export Inspection ..... X X X X Extracts X X X X X X X X Extracts X X X X
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