9911796707
TMI Blog2014 (5) TMI 595X X X X Extracts X X X X X X X X Extracts X X X X ..... ertificate was not issued, but in due course, the Recognition Certificate was issued - Schemes were for the welfare of the employees which cover the substantial life insurance of the employees of Textile unit - The expenditure is allowable as a business expenditure under the Act - on merit, the claim of the assessee is allowable - thus, there is no reason to interfere with the order passed by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act, 1961, is sustainable in law? (b) Whether the ITAT was right in giving a finding that re-opening of assessment was on grounds of change of opinion only when it was not so? The brief facts of the case are that for the assessment year under consideration, the assessee had filed return on 27.10.1997, where it was shown that the premium of Rs. 56,11,336/- was paid against the Group Insurance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tional circumstances were not established by the department. Further, the Tribunal observed that for the LIC policy in question, at the relevant time, Recognition Certificate was not granted, but subsequently, scheme was approved which provides a provision of substantial life cover to the employees. Finally, the claim of the assessee was allowed. Not being satisfied the department filed the pres ..... X X X X Extracts X X X X X X X X Extracts X X X X
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