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TMI Blog2009 (7) TMI 1281X X X X Extracts X X X X X X X X Extracts X X X X ..... 1985-86, it had claimed a deduction of purported consultancy fee of ₹ 14,45,927 allegedly paid to M/s. Turcon India (P.) Ltd. It was claimed that this amount was paid as consultancy fee to the aforesaid firm for getting some contracts from NTPC. The Assessing Authority in his assessment order disallowed the aforesaid expenditure on the ground that the assessee could not furnish sufficient ev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act, no satisfaction was recorded by the Assessing Authority in the assessment order about the fulfilment of requirements contained in section 271(1)(c) of the Act. 2. This matter along with certain other connected matters was referred to Full Bench for decision on the following questions of law:- Whether satisfaction of the officer initiating the proceedings under section 271 of the Incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and (c ) before the proceedings are concluded. It is true that mere absence of the words I am satisfied may not be fatal but such a satisfaction must be spelt out from the order of Assessing Authority as to the concealment of income or deliberately furnishing inaccurate particulars. In the absence of a clear finding as to the concealment of income or deliberately furnishing inaccurate particular ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ind that the Assessing Authority disallowed the aforesaid expense by observing that there was no corroborative evidence justifying the payment of the said amount of ₹ 13 lakhs for genuineness business cause. The order reflects that evidence which was sought to be given by the assessee in support of the aforesaid was not believed and was not treated as sufficient evidence discharging the obli ..... X X X X Extracts X X X X X X X X Extracts X X X X
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