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2019 (8) TMI 362

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..... given that the consumption of stock did not match with the items produced by the Assessee - HELD THAT:- Assessee s appeal was allowed by the CIT(A) by an order dated 3rd March, 2015 inter alia on the ground that before invoking Section 145, the AO had not given any opportunity to the Assessee and therefore, could not have drawn an adverse influence against it. The ITAT observed on merits that .....

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..... S. MURALIDHAR AND TALWANT SINGH JJ. Appellant Through: Mr. Ruchir Bhatia, Advocate Respondent Through: Mrs. Mehkhala Benny, Mr. Kislaya Parashar and Ms. Umang Luthra, Advocates O R D E R 1. The Revenue is in appeal against the order dated 10th December, 2018 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No. 3375/Del/2015 for Assessment .....

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..... 80IC of the Income Tax Act, 1961 ( the Act ). It was held that the books of account maintained by the Assessee could not be relied upon. The deduction under Section 80IC was disallowed and an estimate was made on the expenses incurred and then added to the income of the Assessee under Section 69C of the Act. 4. The Assessee s appeal was allowed by the Commissioner of Income Tax (Appeal) [ .....

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..... fect of the higher profit has not been identified by the learned assessing officer. No indication has also been drawn by the assessing officer that how the assessee has inflated its profit and correspondingly inflated its assets or deflated its liabilities. According to us, this is the simple accounting concept which should have been followed by the learned assessing officer before making the addi .....

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