9911796707
TMI Blog2017 (12) TMI 1668X X X X Extracts X X X X X X X X Extracts X X X X ..... iew that to the extent the interest relate to the investment, i.e. being disallowable under Section 57 will become part of cost of acquisition of shares and therefore the AO is directed to take it as part of the cost of shares for determining profit on sale of the shares. Thus, the additional ground stands allowed to that extent. Addition on account of personal household expenses - HELD THAT:- We find that the addition made by the AO as well as sustained by the CIT(A) are though on ad-hoc basis, but same was done because no details of expenditures was filed by the appellant. Before us, the Ld. Counsel has submitted that, most of the expenses have been incurred by Dr. Hitesh S. Mehta and other family members living in a Joint family set-up. Further other members have contributed for household expenses and that some of the additions have been confirmed on account of personal household expenses by the Department. On these facts and circumstances, we are inclined to scale down the additions to 3 lakhs. Accordingly, addition sustained on account of personal household expenses would be 3 lakhs. Levy of interest under Section 234A, 234B and 234C as well as calculation of the said interest ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the following additional ground: - "Whether in facts and circumstances of the case, the Ld. Assessing Officer and Ld. CIT(A) ought to have granted capitalization of interest expenses attributable to shares and securities which is not allowable u/s 57(iii) of the Act." Similar additional ground was taken by the assessee in each of the case except one more additional ground taken in the case of Ms. Jyoti H. Mehta and Shri Ashwin S. Mehta wherein the assessee has taken one more additional ground. So far as the additional ground is concerned the learned A.R. vehemently contended that the additional ground taken is legal ground and the facts are verified, therefore there this has to be admitted in view of the decision of the Hon'ble Supreme Court in the case of National Thermal Power Co. vs. DCIT 229 ITR 383. The learned D.R., though agitated but could not convince us as to why the ground taken by the assessee in each of the case cannot be admitted. Therefore, in view of the decision of the Hon'ble Supreme Court we admit this additional ground in the case of each of the assessee. 3. In respect of the additional ground the learned A.R. contended that the assessee invested th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the books of accounts have been produced before the AO. 7. Against the said disallowance the assessee went in appeal before the CIT(A). The CIT(A) dismissed the ground relating to deduction of interest on the ground that the assessee has only made provisions for interest but no interest has actually been paid to the creditors. Even the recipients have not offered the said interest in their returns filed before the AO. The interest was not payable as there is no agreement to pay the interest on the borrowed funds. The CIT(A) further held that the assessee has not explained and established the nexus between the interest expenses and the interest income. Otherwise also the issue relating to the interest has to be decided by the Special Court and there is no order of the Special Court directing to pay the interest by the assessee to creditors. 8. Before us the learned A.R. contended that the disallowance of interest made by the AO is without appreciating the facts. He, at the outset, stated that in the original grounds the figures of interest were incorrect and therefore these should be replaced with the figures given in the revised grounds of appeal. Identical issue was raised in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e CIT(A) has accepted the existence of agreement to pay interest on such credit balances. The learned A.R. by referring to the order also contended that the CIT(A) following his own order in the case of M/s. Eminent Holdings Pvt. Ltd. for A.Y. 2007-08 had accepted the contention of the assessee and held that a reasonable nexus can be said to exist between the interest incurred by the assessee and the interest income earned from these assets. The learned A.R. also referring to the order of the CIT(A) dated 29.09.2013 for A.Y. 2006-07 in assessee's own case submitted similar findings were given by the CIT(A) which was not challenged by the Revenue before the Tribunal. The existence of agreement for payment of interest also stands confirmed by the fact that the interest income earned by the creditors have been offered to tax except by Mr. Harshed Mehta since he followed cash system of accounting. It was further submitted that interest income in the hands of recipients were brought to tax in all fairness the interest expenses incurred by the assessee must be allowed. The fact that the Hon'ble Special Court has not granted interest payment, will not have any bearing on allowability ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ue has not relevant for the purpose of deciding the deductibility of expenses but the fact is that the interest payable by the assessee to the creditors Ashwani Mehta and Jyoti Mehta has actually been offered them in their respective returns of income. The learned A.R. also relied on the order of the CIT(A) dated 30.11.2005 in the case of Shri Ashwin S. Mehta for A.Y. 2010-11 wherein the issue relating to taxability of interest income has specifically be discussed and adjudicated. Reliance was also placed on the decision of this Tribunal in the case of M/s. Growmore Leasing & Investment Ltd. vs. ACIT in ITA Nos. 5135 & 5136/Mum/2012 dated 03.05.2015 for A.Y. 2007-08 and 2009-10 wherein this Tribunal has already issued directions that the recipients can be taxed with respect to the income in case if the same is not brought to tax in their assessments. 10. With regard to income in the hands of Late Shri Harshad Mehta, the learned A.R. submitted that Late Shri Harshad Mehta has consistently following cash system of accounting and therefore the Tribunal in his case for A.Y. 1989-90 upheld this issue. Interest income in the case of Late Shri Harshad Mehta shall be offered only when the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... held that there was nexus between the credit balance and the investment in terms deposits. He submitted that following the said order the CIT(A) has also held in assessee's own case in his order dated 29.09.2013 for A.Y. 2006-07 accepting the nexus between such credit balance and investment in term deposits. Thus it was vehemently contended that there was nexus between the amount borrowed and the investment. 11. The learned D.R., on the other hand, contended that the assessee has not filed the return of A.Y. 2009-10. Income has been determined by the AO on the basis of the details filed by the assessee and the computation of income filed before the AO. He relied on the orders of the AO and CIT(A) by mentioning that three firms of Chartered Accountants appointed by the Special Court stated that the loan taken by the Directors are interest free and there are no terms and conditions to pay interest to the creditors on investment. He further stressed that no payment has been made by the assessee to the creditors towards interest and the recipients has also not offered the said interest income to tax. The payment of interest has not been decided by the Hon'ble Special Court and no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the borrowed funds by the assessee to the other family members. We, therefore, reject the plea of the learned D.R. that no liability towards interest has accrued but it was merely a contingent liability. We noted that section 4 of the Special Court Act empowers the custodian and the court to cancel any contract or agreement in relation to the property of a person notified under that Act provided they have entered into fraudulently. In this case no cogent material or evidence has been brought to our knowledge or placed before us which may prove that the custodian under Section 4(1) of the Special Court Act has taken any action to cancel the terms relating to payment of interest. Rather we have noted from the affidavit of the custodian dated 01.03.2006 in M.P. No. 41 of 1999 that the custodian seeking to levy interest @ 15% to 18% per annum. Therefore the interest on outstanding credit balance of the brokerage firm has accrued as actual liability. The issue with regard to contract for payment of interest has been raised by the AO and the CIT(A) in the case of other notified entities duly approve the existence of liability. We noted that in the case of Growmore Leasing & Finance Ltd ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pinion of the AO the corresponding interest income has not been offered by the recipients. The interest can be allowed on the basis of method of accounting followed by the assessee. We noted that similar issue when arose in the case of M/s. Growmore Leasing & Investment Ltd. vs. CIT in ITA No. 51354 & 5136/Mum/2012 wherein the Coordinate Bench of this Tribunal while setting aside the issue to the file of the CIT(A) directed him to tax the income in the hands of recipient family members in accordance with the method of accounting followed by them. We find force in the submission of the learned A.R. that since the assessee as well as the recipients are notified entities under the Special Court Act unless the Court directs for distribution of the assets towards existing liabilities under Section 11(2) of the Special Court Act, the assessee cannot make the payment to these creditors. Even otherwise since the existence of liability towards interest has accrued especially when the assessee is following the mercantile system of accounting the interest is to be allowed. During the course of hearing we raised a query about the nexus of interest expenses with the interest income. The learned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nterest expenses cannot be allowed till the Hon'ble Special Court decide the issue. The allowance or disallowance of the expenditure depends on the accrual of expenditure. Even no dispute has been raised in respect of interest on such credit balances before the Special Court. Even on this basis, following the principle of consistency, as the interest has been allowed as deduction in the A.Y. 2006-07 and there is no change in the facts, the deduction in respect of the interest expenditure has to be allowed. Our aforesaid view is supported by the following decisions: The Supreme Court in the case of Radhasoami Satsang Saomi Bagh vs. CIT 193 ITR 321 referred to the following passage from Hoystead v Commissioner of Taxation 1926 AC 155 (PC), wherein it was observed (page 328): "Parties are not permitted to begin fresh litigation because of new view they may entertain of the law of the case, or new versions which they present as to what should be a proper apprehension by the court of the legal result either of the construction of the documents or the weight of certain circumstances. If this were permitted, litigation would have no end, except when legal ingenuity is exhausted. I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... litigation for the sake of it." 16. In view of our aforesaid discussion we set aside the order of the CIT(A) and direct the AO to allow deduction in respect of said interest accrued and calculated at 12% per annum amounting to ₹ 2,64,72,208/- after disallowing proportionate interest in respect of the investment in shares amounting to ₹ 3,51,176/- after verifying the calculation of the interest quantification. 17. Now coming to the additional ground raised with respect to capitalization of interest we are of the view that to the extent the interest relate to the investment, i.e. being disallowable under Section 57 will become part of cost of acquisition of shares and therefore the AO is directed to take it as part of the cost of shares for determining profit on sale of the shares. Thus, the additional ground stands allowed to that extent. 18. Ground No. 2 Relates to sustenance of the addition on account of personal household expenses by the CIT(A) to the extent of ₹ 6,00,000/-. The facts relating to this issue are that the AO made an addition on estimate basis on account of the personal household expenses at ₹ 12,00,000/- by applying provisions of Section ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... no details of expenditures was filed by the appellant. Before us, the Ld. Counsel has submitted that, most of the expenses have been incurred by Dr. Hitesh S. Mehta and other family members living in a Joint family set-up. Further other members have contributed for household expenses and that some of the additions have been confirmed on account of personal household expenses by the Department. On these facts and circumstances, we are inclined to scale down the additions to ₹ 3 lakhs. Accordingly, addition sustained on account of personal household expenses would be ₹ 3 lakhs. Accordingly, the ground No.5 of the appellant is partly allowed." Respectfully following the said order of the Tribunal we reduce the disallowance sustained by the CIT(A) by 50%, i.e. ₹ 3,00,000/-. Thus, ground No. 2 is partly allowed. 20. Ground Nos. 3 & 4 relate to levy or interest under Section 234A, 234B and 234C as well as calculation of the said interest. We find that the said issue has been decided by the Coordinate Bench in the case of Eminent Holding P. Ltd. in ITA No. 2139/Mum/2013 for A.Y. 2002-03 in which this Tribunal while dealing with the said issue held as under: - " ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... we direct the AO to recomputed the interest liability after reducing the amount of tax deductible at source on the income earned. Thus, ground No. 3 stand dismissed while ground No. 4 stand partly allowed. 21. Thus, the appeals filed by the assessee for assessment years 2009- 10, 2010-11 and 2011-12 are partly allowed. Shri Hitesh S. Mehta - ITA No. 4430/Mum/2017 22. Since the first ground relating to taxing of the income in the hands of Late Shri Harshad S. Mehta is not pressed by the assessee, the same is dismissed as not pressed. 23. Ground No. 2 is similar to the ground No. 1 in the case of Shri Sudhir S. Mehta in ITA No. 5799/Mum/2015. As agreed by both the parties that whatever view may be taken in the case of Sudhir S. Mehta in ITA No. 5799/Mum/2015, the same view may be taken in the case of the assessee. We, therefore, respectfully following our finding given while disposing of ground No. 1 in the case of Sudhir S. Mehta in ITA No. 5799/Mum/2015 set aside the order of the CIT(A) and direct the AO to allow deduction to the under Section 57 in respect of interest accrued @12% amounting to ₹ 1,10,86,8343/- out of the interest earned on term deposit after verifying ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n A.Y. 2013- 14 the assessee has claimed interest of ₹ 1,35,62,185/- after proportionate disallowance of interest of ₹ 6,15,151/- in place of ₹ 1,08,72,373/- after disallowance of proportionate interest of ₹ 33,04,963 in A.Y. 2011.12. Both the parties agreed that as the facts and claim of interest is similar to ground No. 1 in the case of Shri Sudhir S. Mehta in ITA No. 5799/Mum/2015, the same view may be taken in the case of the assessee. While disposing of ground No. 1 relating to claim of interest of assessee in the case of Shri Sudhir S. Mehta we have allowed the claim of interest against interest on term deposit and confirmed proportionate disallowance of interest. We, therefore, respectfully following the decision of this Tribunal in the case of Shri Sudhir S. Mehta in ITA No. 5799/Mum/2015 set aside the order of the CIT(A) and allowed deduction of interest as claimed by the assessee out of the interest on term deposit after disallowing the proportionate interest disallowed to be treated as cost of acquisition of shares and securities. Respectfully following the said decision of the Tribunal in the preceding paragraphs, we allow the deduction of intere ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... udication. As agreed by both the parties that all these appeals be decided on the basis of the facts relating to A.Y. 2004-05, we therefore reproduce the surviving grounds for A.Y. 2004-05 as under: - "1. The Ld. Commissioner of Income-Tax (Appeals) ought to have allowed the deduction of interest expenditure to the extent of ₹ 32,72,218/- as follows: Sr. No. Entities Outstanding amount payable Interest @ 12% p. a. payable 1. Ashwin S. Mehta 5,62,86,358 67,54,363 2. Harshad S. Mehta 6,68,35,833 80,20,300 Total 12,31,22,192 1,47,74,663 Less: Proportionate disallowance of interest u/s. 14 A of the Act 1,15,02,445 Total 32,72,218 4. The Ld. Commissioner of Income-Tax (Appeals) has erred in law and in facts that in confirming the levy of interest u/s. 234A, 234B and 234C of the Act. 5. The Ld, Commissioner of Income-tax (Appeals) has erred in law and in facts in not appreciating that the income assessed in the hands of the appellant were subjected to the provisions of TDS and hence on the said amount of tax no interest can be computed u/s. 234B and 234C of the Act." Similar grounds have been taken relating to the issue about the claim of interest expendit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as arisen in the case of Shri Sudhir S. Mehta in ITA No. 5799/Mum/2015 for A.Y. 2009-10. Therefore the Tribunal may take the same view in the case of the assessee also. We, therefore, respectfully following our order in the preceding paragraph in ITA No. 5799/Mum/ 2015 dismiss ground relating to levy of interest and direct the AO to recompute the interest in accordance with our direction given in the case of Sudhir S. Mehta in ITA No. 5799/Mum/2015 while disposing off ground relating to calculation of interest is concerned. Thus this ground in each of the assessment year is statistically allowed. 36. In the result, appeals filed by the assessee are partly allowed for statistical purposes. Smt. Deepika A. Mehta - ITA Nos. 418/Mum/2016 & ITA No. 2736/Mum/2017 37. In these cases in A.Y. 2011-12 the assessee has taken as many as five grounds of appeal. Ground No. 1 since not pressed stands dismissed as not pressed thereby surviving the following grounds: - "2. The Ld. Commissioner of Income-Tax (Appeals) ought to have allowed the deduction of interest expenditure to the extent of ₹ 1,35,81,461/- as follows: Sr. No. Entities Outstanding amount payable Interest @ 12% p. a. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee. 39. The assessee has taken additional ground in both the assessment years relating to the disallowance of proportionate interest which has been claimed by the assessee to be capitalised towards the cost of shares and securities. As both the parties agreed that similar issue has arising in the case of Shri Sudhir S. Mehta in ITA No. 5799/Mum/2015 for A.Y. 2009-10 and whatever view this Tribunal may take in the case of Shri Sudhir S. Mehta the same view may be taken in the case of the assessee also. We therefore respectfully following the said decision of the Tribunal in the case of Shri Sudhir S. Mehta direct the AO to treat the proportionate interest disallowed in each assessment year to be part of cost of acquisition of shares and securities. Thus the additional ground in each of the assessment year stand allowed. 40. The next issue raised in the two grounds in both the years relate to levy and calculation of interest under Section 234A, 234B and 234C. As agreed by both the parties that similar ground has arisen in the case of Shri Sudhir S. Mehta in ITA No. 5799/Mum/2015 for A.Y. 2009-10. Therefore the Tribunal may take the same view in the case of the assessee also. W ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cts and circumstances of the case, the Ld. Assessing officer and Ld.CIT(A) ought to have adjudicated the issue of interest income. The correct amount of interest income ought to have been determined to arrive at the correct taxable income as per law. 2. Whether in facts and circumstances of the case, the Ld. Assessing officer and Ld. CIT(A) ought to have granted capitalization of interest expenses attributable to shares and securities which is not allowable u/s 57(iii) of the Act." 45. After hearing the rival submissions, we noted that the additional grounds taken by the assessee go to the root of the matter and no new fact has to be brought on record. We, therefore, in view the decision of Hon'ble Supreme Court in the case of the NTPC Vs. DCIT 229 ITR 383 admit the additional grounds taken by the assessee. 46. In respect of additional ground No. 1 and learned A.R. contended that the interest accrued to him on the advances to various notified entities have not been correctly assessed to tax due to the difficulty caused by notification of the assessee under the provisions of Special Court Act and levying tax on such assessee could not followed properly at the relevant point ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Thus, this ground is statistically allowed. 50. Additional ground 2 is similar to additional ground admitted in the case of ITA No. 5799/Mum/2015 in the case of Shri Sudhir S. Mehta for A.Y. 2009-10 we respectfully following the order in the case of ITA No. 5799/Mum/2015 in the case of Shri Sudhir S. Mehta admit the additional ground No. 2. So far the additional ground No. 1, after hearing the rival submission we noted that this ground is consequential in nature to the ground relating to deduction of interest and therefore has to be admitted as all the facts are available regarding interest by other family members. We, therefore, admit the same to tax correct income and income may not escape tax in the hands of the assessee. 51. So far as the ground relating to the claim of interest after disallowing proportionate interest is concerned in both the assessment years, both the parties agreed that similar issue has arising in ground 1 in ITA No. 5799/Mum/2015 in the case of Shri Sudhir S. Mehta and whatever view this Tribunal may take in the case of Shri Sudhir S. Mehta same may be taken in the case of the assessee. While disposing of the appeal for A.Y. 2009-10 ITA No. 5799/Mum/20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /Mum/2015 while disposing off ground No. 4in both the years. Thus ground No. 5 is statistically allowed. 55. In the result, appeals filed by the assessee are partly allowed for statistical purposes. M/s. Growmore Leasing & Investment Ltd. - ITA 1219/Mum/2017 56. In this case the assessee has taken the following revised ground of appeal: - "2. The Ld. Commissioner of Income-Tax (Appeals) ought to have allowed the deduction of interest expenditure to the extent of interest income i.e. ₹ 1,43,721/- as follows: Sr. No. Entities Outstanding amount payable Interest @ 12% p. a. payable 1. Jyoti H. Mehta 25,06,82,692 3,00,81,923 2. Harshad S. Mehta 61,60,61,525 739,27,383 Total 86,67,44,217 10,40,09,306 Less: Proportionate disallowance of interest u/s. 14 A of the Act 2,12,47,194 Total 8,27,62,112 3. The Ld. Commissioner of Income-Tax (Appeals) has erred in law and in facts that in confirming the levy of interest u/s. 234A, 234B and 234C of the Act. 4. The Ld, Commissioner of Income-tax (Appeals) has erred in law and in facts in not appreciating that the income assessed in the hands of the appellant were subjected to the provisions of TDS and hence on the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the extent of ₹ 1,43,721/- after proportionately disallowing a sum of ₹ 2,12,47,194/- and give similar direction to the AO as given in ITA No. 5799/Mum/2015. Thus, ground No. 1 is allowed. 61. So far as the additional ground is concerned as agreed by both the parties, similar additional ground has been taken in ITA No. 5799/Mum/2015 in the case of Shri Sudhir S. Mehta for A.Y. 2009-10. We, respectfully following our decision in that case direct the AO to treat the proportionate interest which stands disallowed while disposing of ground No. 1 as part of cost of shares and securities. 62. Ground No. 2 & 3 relate to levy and calculation of interest under Section 234A, 234B and 234C of the Income Tax Act. As agreed by both the parties, similar issue has arisen in ITA No. 5799/Mum/2015 in the case of Shri Sudhir S. Mehta for 2009-10. We, therefore, respectfully following the said decision dismiss ground No. 2 regarding levy of interest but direct the AO in respect of ground No. 3 that the interest levied under Section 234A, 234B and 234C be recomputed after excluding the income which is subject to TDS. Thus, this ground is allowed for statistical purposes. Shri Ashwin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that only a sum of ₹ 6,37,325/- remained unexplained. Therefore, the CIT(A) reduced the said addition to ₹ 6,37,325/-. 66. The learned A.R. before us contended that similar issue has arisen in the case of Smt. Jyoti H Mehta and in that case the CIT(A) has restored this issue to the file of the AO. We, therefore, in the interest of justice and fair play to both the parties restore this issue regarding non explaining the entries in the bank account to the extent of ₹ 6,37,325/- to the file of the AO with the direction that the AO shall redecide this issue after considering the submission of the assessee and in case the assessee has adduced evidences and explained the nature in respect of such entries to his satisfaction, the addition may be deleted. Thus, this ground is allowed for statistical purposes. 67. Ground No. 3 relates to the claim of interest to the extent of ₹ 1,47,13,638/- after proportionate disallowance of ₹ 8,39,99,631/- out of the interest income earned by the assessee on term deposit. Both the parties agreed that this issue has arisen in ITA No. 5799/Mum/2015 in the case of Shri Sudhir S. Mehta for A.Y. 2009-10 and therefore whatever ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vying tax on such assessee could not followed properly at the relevant point of time. Even the AO failed to calculate the interest income earned by the assessee from the family members who were assessed under his charge. The correct amount of interest to be assessed in the hands of the assessee. 72. The learned D.R., on the other hand relied on the order of the Tax Authorities below. After hearing and carefully considering the rival submissions, we are of the view that the correct interest income has to be assessed in the hand of the assessee. The assessee has given the calculation of interest income which has to be assessed amounting to ₹ 10,68,83,731/-. We, therefore, set aside this issue and restore this issue to the file of the assessee and direct the AO to recalculate the interest income in the hands of the assessee and treat the correct income to be the income of the assessee from interest which has accrued to the assessee from various family members in whose hands the said income has been allowed as deduction. Thus, this ground is allowed for statistical purposes. 73. The additional ground No. 2 relates to capitalization of interest expenses. Similar issue has arisen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubject to provisions of TDS. Thus ground No. 6 is statistically allowed. 78. In A.Y. 2004-05 also the assessee has filed two revised grounds which identical to ground Nos. 1 & 2 of A.Y. 2003-04 except change in figure in ground No.2. Ground No. 1 since not pressed, dismissed as not pressed. In respect of ground No. 2 both the parties agreed that similar issue has arising in ITA No. 5799/Mum/2015 in the case of Shri Sudhir S. Mehta and whatever view this Tribunal may take in that case, the same view may be taken in the case of the assessee. Since in the case of Shri Sudhir S. Mehta while disposing off similar ground relating to interest expenditure we allowed the deduction to the assessee out of the interest earned on term deposit. Respectfully following our said order in the preceding paragraph we direct the AO to allow deduction to the assessee amounting to ₹ 20,90,180/- out of the interest on term deposit by following our similar direction given therein. Thus, this ground to that extent is allowed. 79. In both the assessment years i.e. 2003-04 and 2004-05 the assessee has taken two additional grounds similar to the additional grounds taken in A.Y. 2002-03. Since these gro ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
