9911796707
TMI Blog2014 (5) TMI 231X X X X Extracts X X X X X X X X Extracts X X X X ..... he Income Tax Appellate Tribunal ("the Tribunal" for short) raising the following substantial questions of law: (i) Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in upholding the order of the CIT(A), restricting the disallowance of Rs.33,19,203/- to Rs.59,000/- without appreciating that the assessee had failed to discharge its primary onus of pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... out appreciating that the finding of AY 2001-02 was based on completely distinguishable facts and hence inapplicable to the year under consideration? (iv) Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in upholding the order of the CIT(A), restricting the disallowance of Rs.33,19,203/- to Rs. 59,000/- relying on the ITAT's order in AY 2001-02, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red the information and realised that there were 31 persons to whom the discount was paid on the last date of the accounting period. Names and addresses of those persons were though furnished, confirmation did not come from these persons. Notices were issued under section 133(6) to all these persons, which was partially complied with and accordingly the Assessing Officer had taxed sum of Rs.33.19 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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