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TMI Blog2013 (4) TMI 63X X X X Extracts X X X X X X X X Extracts X X X X ..... e out of the total bills which is fraction which pertains to the assessee were debited to the assessee by crediting to the expenses account by M/s. Holy Faith International Pvt. Ltd is not under dispute. The expenses have been claimed only at one place by the assessee is also not under dispute. Both the concerns are being taxed at highest slab is not under dispute & also assessee is having machinery which is part of the asset side of the balance sheet and, therefore, one cannot imagine that there will be not expenditure of machinery maintenance. Thus the debit note issued by M/s. Holy Faith International Pvt. Ltd has rightly been claimed by the assessee as an expenditure. The A.O. is directed to allow the same and accordingly the order of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /s. Holy Faith International Pvt. Ltd. having common business premises and installation of parts of machinery with assessee's concern. 2. That the ld. Assessing Officer has erred in no considering that it would not matter if a sum of Rs.60,000/- is allowed an expenditure in the hands of M/s. Holy Faith International Pvt. Ltd. or in the hands of M/s. Gulab Singh Sons (P) Ltd. because both the concerns fall in same income bracket and there is no tax benefit to either of the group concerns. 3. That the ld. CIT(A) has erred in upholding in not allowing credit of TDS amounting to Rs.55,510/-. 4. That notwithstanding above said grounds of appeal the ld. CIT(A) alternatively has erred in not giving findings to allow the credit of TDS of Rs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the assets side of the balance sheet. The expenses having been incurred by M/s. Holy Faith International Pvt. Ltd; being the sister concern having common premises for which all the details of the expenses having been submitted in the case of M/s. Holy Faith International Pvt. Ltd; and no dispute is there in this regard in the assessment of M/s. Holy Faith International Pvt. Ltd. M/s. Holy Faith International Pvt. Ltd; issued debit note out of such expenses pertaining to the assessee which are allowable in the hands of the assessee since all the details are available with M/s. Holy Faith International Pvt. Ltd; being small expenses like Nuts, bolts, Gear, Element, Patti, Bearings, Tools, Beeding and Grease etc. for which separate billing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vt. Ltd; for which all the details are available with M/s. Holy Faith International Pvt. Ltd. The expenses pertaining to the assessee out of the total bills which is fraction which pertains to the assessee were debited to the assessee by crediting to the expenses account by M/s. Holy Faith International Pvt. Ltd; is not under dispute. The expenses have been claimed only at one place by the assessee is also not under dispute. Both the concerns are being taxed at highest slab is not under dispute. It is also not under dispute that the assessee is having machinery which is part of the asset side of the balance sheet and, therefore, one cannot imagine that there will be not expenditure of machinery maintenance. In the facts and circumstances of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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