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2013 (4) TMI 191

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..... Section 40-A of the Act could not have been invoked as no payment has been made to the sister concerns for any item of expenditure, which the assessee might have claimed as revenue expenditure - The Tribunal found that a tax payer can manage his affairs to reduce tax liability within the frame work of law and that the sale of goods at a lesser price to the sister concerns than to the non-sister c .....

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..... an those to non-sister concerns?" The assessee filed his return of income on 09.10.2006 showing the income of Rs.5,12,954/-. The Assessing Officer vide its order dated 06.11.2008 made addition of Rs.60,72,118/- on account of profit at the rate of 15% in respect of the sales made to sister concerns, on account of difference in rate of sale as compared to non-sister concerns. The Commissioner of .....

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..... bility within the frame work of law and that the sale of goods at a lesser price to the sister concerns than to the non-sister concerns, does not violate any provision of law. We do not find that the findings recorded by the Tribunal, raise any substantial question of law. The assessee has not violated any provision of law while making sales to its sister concerns at lesser rate that to non sist .....

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