9911796707
TMI Blog2015 (5) TMI 151X X X X Extracts X X X X X X X X Extracts X X X X ..... o verification by AO and further the decision of ld. CIT(A) on the issue to be cryptic. We also find that ld. CIT(A) had directed the A.O to verify the figures and thereafter allow the loss of the amount actually written off in the books. On the issue of setting aside by CIT(A), it is to be noted that the Finance Act, 2001 has w.e.f. 1st June, 2001 withdrawn the power of CIT(A) to set aside the assessment and refer the case back to the AO for making a fresh assessment in accordance with the directions given by CIT(A). In view of the aforesaid amendment made by Finance Act 2001, we are of the view that Ld. CIT(A) does not have power to remand and therefore we do not approve the action of ld. CIT(A) in remitting the issue to the file of A.O. However at the same time, it is also a fact that before us, no details of the bad debts claimed have been filed by the assessee and therefore we are also unable to peruse the details and decide the issue at our end. Considering the aforesaid facts and in the interest of justice, we are of the view that the factual aspect needs re-examination at the end of A.O. - Decided in favour of assessee for statistical purposes. Disallowance of expenditur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pellant is entitled to higher claim of depreciation instead of loss on assets. Any notional or actual scrap value or sale of assets is to be reduced from the opening WDV for purposes of depreciation. It is also to be appreciated that in case a block is empty or has no WDV, no depreciation is admissible. Although it is emphasized before me that all the items are revenue in nature but in the absence of details, this fact could not be verified. The appellant is directed to provide necessary details to the AO and elaborate that none of the capital items is part of the loss claimed and that the capital items have been suitably considered in the depreciation calculation and is not part of the loss claimed. However if there are capital items which are claimed as loss these would stand disallowed with corresponding higher depreciation as per provisions of sec.32, 2(11), 43(1) and 43(6). - Decided in favour of assessee for statistical purposes. Disallowance of loss on Exchange rate variation - Held that:- The issue is now covered against Assessee by the decision of Apex Court in the case of ACIT vs. Elecon Engg. Co. Ltd. (2010 (2) TMI 23 - SUPREME COURT OF INDIA) and therefore the issue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nience and thus proceed by referring to the facts for A.Y. 1999-2000 in ITA No. 1087/AHD/2011. 3. The relevant facts as culled out from the material on record are as under. 4. Assessee is a company stated to be engaged in the business of generation and distribution of electricity. Assessee filed its original return of income for A.Y. 1999-2000 on 28.12.1999 declaring total income at Rs. Nil after setting off of unabsorbed depreciation of earlier years. Subsequently, a revised return was filed on 01.09.2000 and the loss was revised at ₹ 340,36,33,232/-. The case was selected for scrutiny and thereafter the assessment was framed under section 143(3) vide order dated 28.03.2002 and the total loss was determined ₹ 246,31,70,566/-. Aggrieved by the order of A.O., Assessee carried the matter before ld. CIT(A) who vide order dated 16.02.2011 granted partial relief to the Assessee. Aggrieved by the aforesaid order of ld. CIT(A) Assessee is now in appeal before us and has raised the following grounds:- 1. The learned Commissioner of Income Tax (Appeals) erred in law and on facts has confirmed the disallowance of prior period expenses amounting to ₹ 51,04,89,092/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal. 5. Subsequently, vide letter dated 3rd July, 2014, Assessee has raised an additional ground which reads as under:- The employees' cost of ₹ 4,75,22,871/- ought to be allowed in Asst. Year 1999-2000 in view of the following finding of the Assessing Officer in his assessment order for the Asst. Year 1998-99:- As regards, the employees cost of ₹ 4,75,22,871/-, on perusal of the General Standing Order No. 325 dated 3.6.1998, it is noted that the order is issued beyond the period of the previous year and the payment of arrears w.e.f. 1.1.1996 to the date of issue of the order will be paid by July, 1998, that too beyond the period of the previous year and thus, if at all the contention of the assessee is considered, the liability is crystallized in the subsequent year, i.e. in assessment year 1999-2000. As such, the claim of the assessee cannot be entertained and thus accordingly rejected. 6. The reason for taking up additional ground was stated that the AO while framing the assessment for A.Y. 1998-99 had disallowed the claim of expenses for the reason that according to him the claim arises in A.Y. 1999- 2000. The Ld. AR therefore submitted that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubmitted that since the facts of the case in the year under consideration are identical to that of A.Y. 97-98, following the order of Hon'ble Tribunal for A.Y. 1997-98, the issue may be remitted to the file of A.O. He also placed reliance on the decision in the case of Saurashtra Cement Chemical vs. CIT (1995) 213 ITR 523 (Guj.) Ld. D.R. on other hand pointed to the findings of A.O and submitted that the onus lies on the assessee to substantiate its claim and in the absence of details filed by the Assessee, A.O was fully justified in making a disallowance. He thus supported the order of A.O and ld. CIT(A). 10. We have heard the rival submissions and perused the material on record. In the present case, the expenses were disallowed by the AO for the reason that Assessee did not furnish the required details and justify the claim of expenses. We find that in A.Y. 97-98 similar issue of disallowance of prior period expenses was before the co-ordinate Bench of Tribunal. The co- ordinate Bench of Tribunal vide order dated 26.06.2009 had set aside the issue to AO by holding as under:- 2. The first ground is against the disallowance of the prior period expenses of ₹ 91,70, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee of bad debts cannot be allowed. He accordingly disallowed the claim of bad debts of ₹ 3,81,76,827/-. Aggrieved by the order A.O, Assessee carried the matter before ld. CIT(A) who decided the issue by holding as under:- 6. The third ground of appeal is against disallowance of ₹ 3,81,76,827/- being bad debts. 6.1 AO mentions that assessee had claimed deduction of ₹ 2,71,31,732/- as actual bad and doubtful debts written off whereas actual write off works out to ₹ 23,31,40,205/-. Further provision amounting to ₹ 3,81,76,827/- was not added to the computation of income and neither written off which was thus added as disallowable provision. 6.2 In appeal, it is submitted that the actual bad debts written off during the year was ₹ 30.94 crores (27.13+3.82). The opening provision was 97.17 crore and the closing provision was ₹ 93.36 crore and the provision during the year charged to P L was ₹ 27.13 crore. 6.3 I have carefully considered the facts of the case, the submissions of the appellant and the assessment order. Prima facie the contention of appellant seems to be correct. The AO may verify the figures from the sche ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ptly filing and submitting all the details called for by them. In case the details are not furnished by Assessee, then A.O shall be free to decide the issue based on the material on record. In the result, this ground of Assessee is allowed for statistical purposes. Ground no. 3 is with respect to disallowance of expenditure incurred on rehabilitation and restoration work as a result of cyclone. 16. On perusing Schedule 16 of the annual statement of accounts, A.O noticed that Assessee had claimed loss of ₹ 21,91,00,234/- on account of flood, cyclone, fire etc and extraordinary credit of ₹ 10 crore under the head subsidy against losses . A.O also noted that before him it was admitted that the losses claimed were based on the estimate and that Government of Gujarat had granted an amount of ₹ 10 crore against the losses. A.O in the order has noted that the Assessee did not produce anything to establish that the loss claimed by the Assessee were actual losses and were not merely an estimate and was therefore of the view that the losses on the basis of provision are not allowable. He accordingly disallowed the claim of loss. With respect to the grant of ₹ 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y be remitted back to ld. CIT(A). The ld. D.R. on the other hand supported the order of AO. 19. We have heard the rival submissions and perused the material on record. We find that the grant of ₹ 10 crore received by the Assessee from Government of Gujarat was considered by the A.O to be cessation of trading liability and therefore taxable under heads of profit and gains of business . We find that this issue has not been decided by ld. CIT(A). With respect to the disallowance of ₹ 21,91,00,234/- on account of flood, cyclone etc, we find that CIT(A) has remitted the issue to be file of AO and further the decision of ld. CIT(A) on the issue to be cryptic. On the issue of setting aside by CIT(A), it is to be noted that the Finance Act, 2001 has w.e.f. 1st June, 2001 withdrawn the power of CIT(A) to set aside the assessment and refer the case back to the AO for making a fresh assessment in accordance with the directions given by CIT(A). In view of the aforesaid amendment made by Finance Act 2001, we are of the view that Ld. CIT(A) does not have power to remand and therefore we do not approve the action of ld. CIT(A) in remitting the issue to the file of A.O. However at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hed by the Assessee. 23. We have heard the rival submissions and perused the material on record. We find that A.O while disallowing the claim has noted that in the absence of details, the nature and liability of the expenses could not be ascertained and determined and therefore he disallowed 10% of the expenses. We also find that the decision of ld. CIT(A) on the issue to be cryptic and further the matter was allowed subject to verification by A.O. On the issue of setting aside by CIT(A), it is to be noted that the Finance Act, 2001 has w.e.f. 1st June, 2001 withdrawn the power of CIT(A) to set aside the assessment and refer the case back to the AO for making a fresh assessment in accordance with the directions given by CIT(A). In view of the aforesaid amendment made by Finance Act 2001, we are of the view that Ld. CIT(A) does not have power to remand and therefore we do not approve the action of ld. CIT(A) in remitting the issue to the file of A.O. However at the same time, it is also a fact that before us, no details of the losses and its nature have been filed by the assessee and therefore we are also unable to peruse the details and decide the issue at our end. Considering t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o employees of GSECL and is thus does not allowable. In addition the provision of doubtful debt of ₹ 0.25 crore is merely a provision and cannot be allowed. The A.O. also mentioned that ₹ 8.16 crores of miscellaneous receipts was not accounted for though services were rendered in execution of works. Thus ₹ 9.28 crore was added to the total income. 9.2 In appeal it is submitted that alleged understatement of profit is only due to the accounting entries made in the books of accounts and that there is no question of adding back the amount to the profit. It is also contended that necessary effect of the understatement of entries have been given in assessment year 2000-01 and that if the addition is confirmed in the instant year the same should be deleted in A.Y. 2000-01. 9.3 I have carefully considered the facts of the case, the submissions of the appellant and the assessment order. The rationale and the basis for various additions/disallowances by A.O. on issues raised by C A G is perfectly in order as the assessee is following mercantile system of accounting. Addition of ₹ 9.28 crore is thus confirmed. However, the alternate plea of the appellant is ac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of hearing to the Assessee. We also direct the Assessee to co-operate with the Revenue authorities by promptly filing and submitting all the details called for by them. In case the details are not furnished by Assessee, then A.O shall be free to decide the issue based on the material on record. In the result, this ground of Assessee is allowed for statistical purposes. Ground no. 6 is with respect to disallowance u/s. 43B. 28. A.O noticed that Assessee has claimed payment of bonus as an expense. He also noticed that company had paid bonus of ₹ 1,18,18,588/- but in the computation of income had claimed deduction of ₹ 1,28,24,131/-. The Assessee was asked to furnish the evidence in respect of excess amount claimed in the computation of income on account of bonus payment. A.O noted that since the Assessee did not furnish any evidence, the excess payment of ₹ 10,05,543/- was disallowed u/s. 43B of the Act. Aggrieved by the order A.O, Assessee carried the matter before ld. CIT(A) who decided the issue by holding as under:- 10.3 I have carefully considered the facts of the case, the submissions of the appellant and the assessment order, The appellant is direct ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Assessee reads as under:- The employees' cost of ₹ 4,75,22,871/- ought to be allowed in Asst. Year 1999-2000 in view of the following finding of the Assessing Officer in his assessment order for the Asst. Year 1998-99:- As regards, the employees cost of ₹ 4,75,22,871/-, on perusal of the General Standing Order No. 325 dated 3.6.1998, it is noted that the order is issued beyond the period of the previous year and the payment of arrears w.e.f. 1.1.1996 to the date of issue of the order will be paid by July, 1998, that too beyond the period of the previous year and thus, if at all the contention of the assessee is considered, the liability is crystallized in the subsequent year, i.e. in assessment year 1999-2000. As such, the claim of the assessee cannot be entertained and thus accordingly rejected. 33. Before us, ld. A.R. has submitted that the additional ground be adjudicated, in view of the fact that its claim in earlier year 98-99 came to be disallowed only for the reason that according to A.O it arose in A.Y. 1999-2000. Before us, ld. A.R. has also given an undertaking that the Assessee will not press the additional ground now taken in assessment year ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1088/Ahd/2011) reads as under:- 1. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the disallowance of Bad Debts of ₹ 14,95,34,791/- despite the fact that all the facts necessary for deciding the issue were submitted at the time of hearing of the appeal. 2. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the issue relating to the disallowance of ₹ 1,34,882/- being purchase of small and low value items below ₹ 500/-without assigning any cogent reasons whatsoever. 3. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the issue relating to the disallowance of ₹ 49,04,039/- being amount of shortages on physical verification of stock and pilferage of stock on the ground that details justifying that the same are revenue in nature may be filed before the Assessing Officer. 4. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the disallowance of ₹ 4,44,69,750/- being loss on account of fixed assets destructed due to floods, cyclone etc., on the ground that the nece ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... amount of ₹ 75,96,145/- being the loss on sale of fixed assets on the ground that the necessary details may be provided to the Assessing Officer. 7. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the issue relating to the additions of ₹ 104,97,00,000/- on account of the alleged understatement of income which was reported by the C AG in its report despite the fact all the facts necessary for deciding the issue were submitted before the learned Commissioner (Appeals). 39. The grounds raised by Assessee in A.Y. 2002-03 (ITA No. 1090/AHD/2011) reads as under:- 1. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the disallowance of Bad Debts of ₹ 8,,44,02,003/- despite the fact that all the facts necessary for deciding the issue were submitted at the time of hearing of the appeal. 2. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the disallowance of ₹ 8,85,75,392/- being loss on account of loss of fixed assets destructed due to floods, cyclones etc., debited under the head Extra-ordinary Items on the ground ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome Tax (Appeals) has erred in law and on facts in confirming the disallowance of Loss on obsolescence of fixed assets amounting to ₹ 70,344/- treating the same as capital loss. 3. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the issue relating to the disallowance of cost of raising finance amounting to ₹ 2,12,86,344/- on the ground that the appellant may furnish details to the Assessing Officer as to whether the expenditure was of capital nature or revenue nature. 4. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the issue relating to the disallowance of an amount of ₹ 38,28,000/- being the loss on sale of scrap on the ground that the necessary details may be provided to the Assessing Officer. 5. The learned Commissioner of Income Tax (Appeals) erred in law and on facts has confirmed the disallowance of ₹ 22,56,000/- being the waiver of HBA Loans allowed to the employees on the death of the employees while in service on the ground that the same is a capital loss. 6. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iture was of capital nature or revenue nature. 7. The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in setting aside the issue relating to the disallowance of ₹ 6,70,09,792/- being amount of shortages on physical verification of stock and pilferage of stock on the ground that details justifying that the same are revenue in nature may be filed before the Assessing Officer. 43. Before us, ld. A.R. submitted that grounds No. 1, 4 5 in ITA No. 1088/AHD/2011 for A.Y. 2000-01, grounds No. 1, 4, 7 in ITA No 1089/AHD/2011. for A.Y 2001-02, Grounds No. 1, 2 5 in ITA No. 1090/AHD/2011 for A.Y. 2002-03, grounds No. 1 in ITA NO. 1091/AHD/2011 for AY 2003-04, ground No 1 in ITA No 1109/Ahd/2011 for AY 2004-05 and ground No. 1 in ITA No. 1110/AHD/2011 for AY 2005-06 are identical and similar to the grounds raised in ITA NO. 1087/AHD/2011 for A.Y. 1999-2000 except for the amounts and therefore the submissions made by him are also applicable to the aforesaid grounds. The aforesaid submissions of ld. A.R. were not objected to by ld. D.R. In view of the aforesaid facts, and for the reasons given while disposing the appeal for A.Y. 1999-2000 hereinabove ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owed with reference to the opening WDV and the asset lost/discarded is not reduced from the opening WDV. In effect the appellant is entitled to higher claim of depreciation instead of loss on assets. Any notional or actual scrap value or sale of assets is to be reduced from the opening WDV for purposes of depreciation. It is also to be appreciated that in case a block is empty or has no WDV, no depreciation is admissible. Although it is emphasized before me that all the items are revenue in nature but in the absence of details, this fact could not be verified. The appellant is directed to provide necessary details to the AO and elaborate that none of the capital items is part of the loss claimed and that the capital items have been suitably considered in the depreciation calculation and is not part of the loss claimed. However if there are capital items which are claimed as loss these would stand disallowed with corresponding higher depreciation as per provisions of sec.32, 2(11), 43(1) and 43(6). The ground is allowed subject to verification and aforesaid directions. Grounds No. 3, 4 and 5 are allowed subject to verification and aforesaid directions. 45. Aggrieved by the order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d no. 2 3 raised by Assessee in A.Y. 2000-01 and the submissions made by them while arguing the case for A.Y. 2000-01 are also applicable to the present grounds. 50. We have heard the rival submissions and perused the material on record. Before us, since both the parties have submitted that the issue raised in the present grounds being identical to the grounds raised in A.Y. 2000-01, we therefore for the reasons stated herein while disposing of ground no. 2 and 3 for A.Y. 2000-01 and for similar reasons and directions allow the grounds for statistical purposes. Now we take up ground No 5 6 which are considered together. 51. A.O noticed that Assessee has claimed infructuous capital expenses written off of ₹ 15,81,825/- and loss of obsolesce of fixed assets of ₹ 1,20,965/-. A.O was of the view that the expenses being capital in nature was not allowable and accordingly disallowed the same. A.O also noted that Assessee had claimed loss on sale of fixed assets of ₹ 75,96,145/-. A.O was of the view that the same was also not allowable as being capital in nature and accordingly disallowed the claim. Aggrieved by the order of A.O, Assessee carried the matter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT(A). 54. We have heard the rival submissions and perused the material on record. We find that the claim of expenses was disallowed by the A.O as he was of the view that the expenses were of capital in nature. We also find that Ld. CIT(A) decided the ground of Assessee in its favour subject to verification by AO. We also find that the decision of ld. CIT(A) on the issue to be cryptic and he had directed the A.O to verify the figures and thereafter allow the claim of loss. On the issue of setting aside by CIT(A), it is to be noted that the Finance Act, 2001 has w.e.f. 1st June, 2001 withdrawn the power of CIT(A) to set aside the assessment and refer the case back to the AO for making a fresh assessment in accordance with the directions given by CIT(A). In view of the aforesaid amendment made by Finance Act 2001, we are of the view that Ld. CIT(A) does not have power to remand and therefore we do not approve the action of ld. CIT(A) in remitting the issue to the file of A.O. However at the same time, it is also a fact that before us, no details of the expenses claimed have been filed by the assessee and therefore we are also unable to peruse the details and decide the issue at ou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessment Year 04-05 onwards though it is claimed before me that the funds were raised for existing business, no details could be furnished to establish this fact. The appellant is directed to provide details in this regard to A.O and if found true, ground would stand allowed otherwise the expenses related to expansion of business would need to be capitalized and allowed as depreciation from the year in which assets were first put to use. Ground no. 8 is allowed subject to verification and aforesaid directions. 57. Aggrieved by the order of Ld.CIT(A), Assessee is now in appeal before us. 58. Before us, at the outset, ld. A.R. fairly conceded that the issue is now covered against Assessee by the decision of Apex Court in the case of ACIT vs. Elecon Engg. Co. Ltd. 322 ITR 20 (SC) and therefore the issue has to be decided against the Assessee. 59. We have heard ld. A.R. In view of the submission of ld. A.R. that the issue is covered against the assessee by the decision of H'ble Apex Court. In view of the aforesaid facts, we dismiss the ground of assessee and thus this ground is dismissed. Ground no. 4 is with respect to disallowance of loss of sale of scrap. 60. A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... apart from oral submissions, no details have been filed by the assessee and therefore we are also unable to peruse the details and decide the issue at our end. Considering the aforesaid facts and in the interest of justice, we are of the view that the factual aspect needs re-examination at the end of A.O. We therefore set aside the issue to the file of A.O to decide the issue de novo after considering the submissions of the Assessee and in accordance with law. Needless to state that A.O shall grant adequate opportunity of hearing to the Assessee. We also direct the Assessee to co-operate with the Revenue authorities by promptly filing and submitting all the details called for by them. In case the details are not furnished by Assessee, then A.O shall be free to decide the issue based on the material on record. In the result, this ground of Assessee is allowed for statistical purposes. 64. In the result, the appeal of Assessee in ITA No 1090/A/2011 for AY 2002-03 is partly allowed for statistical purposes. ITA No. 1109/AHD/2011 ( for A.Y. 2004-05) Now we take up remaining grounds of ITA No. 1109/AHD/2011 for A.Y. 2004-05 65. Before us, both the parties submitted that gro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng principles, it can be said to arise out of the carrying on of the business and be incidental to it. The loss for which a deduction is claimed must be one that springs directly from the carrying on of the business and is incidental to it, and not any loss sustained by the assessee even if it has some connection with his business. If that is established, then the deduction must be allowed, provided that there is no provision against it, express or implied, in the Act. 7.3.1 This principle was followed by the Supreme Court in the case of Indore Malwa United Mills Ltd. The key issue is whether the loss claimed arises directly from the carrying on the business or it has some connection with the business. It is submitted before me that the housing loans are disbursed to the employees at interest as a facility and to earn their loyalties and thus the expenditure is for business purposes. The Appellant is in the business of generation and in distribution of power and the advances are not in the course of the carrying on of the business but these are only having some connection with operational efficiency of the business. In my humble opinion the loss claimed is plain and simple capi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xpansion of business would need to be capitalized and allowed as depreciation from the year in which assets were first put to use. Ground no. 8 is allowed subject to verification and aforesaid directions. 74. Aggrieved by the order of CIT(A), Assessee is now in appeal before us. 75. We have heard the rival submissions and perused the material on record. We find that the claim of expenses incurred for raising finance was disallowed by the A.O as he was of the view that the expenses were capital in nature. We also find that Ld. CIT(A) decided the ground of Assessee in its favour subject to verification by AO. We also find that the decision of ld. CIT(A) on the issue to be cryptic. We also find that ld. CIT(A) had directed the A.O to verify the details and thereafter decide the issue. On the issue of setting aside by CIT(A), it is to be noted that the Finance Act, 2001 has w.e.f. 1st June, 2001 withdrawn the power of CIT(A) to set aside the assessment and refer the case back to the AO for making a fresh assessment in accordance with the directions given by CIT(A). In view of the aforesaid amendment made by Finance Act 2001, we are of the view that Ld. CIT(A) does not have power ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
