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TMI Blog1989 (4) TMI 139X X X X Extracts X X X X X X X X Extracts X X X X ..... and disallowance of Rs. 17,600 under s. 80VV. 2. Appearing for the assessee, the learned counsel Mr. N.M. Ranka had provided the copy of the ledger account of the conveyance charges starting from ledger folio 467 and ending with ledger folio 478 and submitted that these are re-imbursement of the conveyance charges incurred by the employees while carrying out their duties in regard to the affairs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... val submission. Sec. 37(3A) covers running and maintenance of air-craft and motor-cars. The Explanation that is provided in cl. (c) relating to the above mentions that it includes expenditure incurred on the charter any air-craft and expenditure on hire charges for engaging cars plied on hire and also conveyance allowance paid to employees including payments to its Directors, in case of a Company. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that would also be covered under this clause for the reason that taxies are cars plying on hire. To our mind, the plea raised though has merit but since the section envisages incurring of hire charges by the company the argument as advanced by the learned Sr. Departmental Representative is not acceptable. We are, therefore, of the view that even sub-cl. (i) of Expln. (c) would not be attracted. As ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for which s. 80VV had been introduced. Therefore, no part of the consultation could be disallowed. He placed reliance on M.P. Udyog Ltd. vs. ITO (1989) 28 ITD 85 (All)(TM). The learned Sr. Departmental Representative placed heavy reliance on the orders of the authorities below. 6. On this issue, after carefully considering the rival submissions, we are of the view that since s. 80VV envisages a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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