TMI Blog1980 (3) TMI 128X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. Facts briefly stated and material for the purposes of the present appeals before us are that the ITO while computing the total income of the assessee for the assessment years under appeal made disallowances out of the expenditure heads as under: . 1974-75 1975-76 Out of coal fuel expenses Rs. 800 Rs. 1,500 Out of land revenue Rs. 767 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he disallowance was sustained. 6. On the next score, i.e., disallowance of land revenue the AAC relied upon the directions given by him in an order made in appeal No. 19 of 5th Aug., 1976, relating to the asst. yr. 1973-74. 7. On the third score, i.e., disallowances out of manufacturing account, the AAC applied the same reasoning i.e. that in view of disallowance having been made in the earlie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and as before and justifiably on facts. He supported the orders of the lower authorities. 10. We having considered the facts of the case as also having perused the orders of the lower authorities are of the view that each assessment year being a separate and independent one the disallowances have to be made and sustained on merits and on facts of each year and 'like last year' is no basis for ma ..... X X X X Extracts X X X X X X X X Extracts X X X X
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