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TMI Blog2021 (8) TMI 609X X X X Extracts X X X X X X X X Extracts X X X X ..... arm s length. Even applying the rule of consistency and past history relating to similar transaction, the export commission paid at 12.5% has to be accepted to be at arm s length. In view of the aforesaid, we are inclined to delete the adjustment made to the ALP of export commission paid to the AE. This ground is allowed. Disallowing full deduction of VRS and early retirement incentive granted to employees - HELD THAT:- As respectfully following the decisions of the co-ordinate bench in assessee s own case,[ 2014 (8) TMI 831 - ITAT MUMBAI] we allow the deduction claimed by the assessee. Disallowance of depreciation on obsolete assets - claim disallowed simply for the reason that similar claim made by the assessee in preceding assessment years has been disallowed - HELD THAT:- As decided in own case [ 2014 (8) TMI 831 - ITAT MUMBAI] depreciation was allowable on obsolete assets to the assessee. Disallowance of interest expenditure u/s 14A - HELD THAT:- We find, while deciding identical issue in preceding assessment years [ 2014 (8) TMI 831 - ITAT MUMBAI] the Tribunal has deleted the disallowance of interest expenditure made under section 14A. Disallowance being expenditure incurred ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d is allowed. Addition/enhancement made to the ALV need to be deleted. Computation of deduction under section 80HHC - As sales tax set off and refund are not eligible for deduction in view of Explanation (baa) to section 80HHC. Therefore, 90% of such receipt has to be excluded from the business profits as well as turnover for computing deduction under section 80HHC. Penalty u/s 271(1)(c) - HELD THAT:- For addition on account of Transfer Pricing adjustment relating to payment of commission as rightly observed by Commissioner (Appeals), such disallowances cannot automatically lead to the conclusion that the assessee has either furnished inaccurate particulars of income or has concealed its income. We also agree with Commissioner (Appeals) that the issues relating to disallowances/additions, based on which penalty has been imposed are debatable issues on which more than one opinion is possible - transfer pricing adjustment was made on purely estimate basis. Thus, as rightly held by learned Commissioner (Appeals), such additions/disallowances, based on difference of opinion, cannot lead to the inference that assessee has either furnished inaccurate particulars of income or concealed it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... res, purchase of patent rights and trademarks from AE in Germany and France, reimbursement of expenses from AE. As it appears, the assessee aggregated the transactions relating to import and exports of active formulations, bulk drugs, payment of commission, etc. and benchmarked them in the transfer pricing study report applying transactional net margin method (TNMM). Since, the operating margin shown by the assessee at 13.83% was more than the mean operating margin of the comparable companies worked out at 7.69%, the transactions were claimed to be at arm's length. Apparently, the TPO accepted the benchmarking of the assessee in respect of all international transactions, except, payment of export commission to AE. Insofar as this transaction is concerned, the TPO has treated it as a completely independent and separate transaction and proceeded to verify whether the export commission paid at 12.5% of the sales is at arm's length or not. In response to query raised, the assessee furnished a detailed submission along with supporting evidence justifying its claim that commission paid at 12.5% on sales is at arm's length. The TPO, however, did not accept the submissions of the assessee. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... export commission should be considered to be at arm's length. He submitted, since payment of commission is closely linked to the transactions of exports and imports, they have to be aggregated for the purpose of benchmarking. Whereas, the TPO has selectively segregated payment of commission as an independent transaction for benchmarking while accepting the other transactions. He submitted, when the TPO has accepted TNMM as the most appropriate method in respect of other closely linked transactions, he should not have segregated the payment of commission. The learned senior counsel submitted, the assessee has been paying export commission from assessment year 1992-93 onwards at the very same percentage and no adjustment has ever been made to the price of commission payment. He submitted, in the year 1999- 2000, the TPO made similar adjustment; however, learned Commissioner (Appeals) allowed the entire commission paid at 12.5% finding it to be at arm's length. He submitted, in assessment year 2005-06, the TPO himself accepted the export commission paid at 12.5% to be at arm's length. Thus, he submitted, rule of consistency has to be followed. 5. The learned departmental representati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the TPO in determining the ALP of export commission at 3% is without any basis and purely on conjectures and surmises. The TPO has not shown any valid reason why assessee's claim that the transactions relating to import and export of formulations and bulk drugs as well as payment of export commission being closely linked, should not be aggregated together for benchmarking purpose. 8. It is also relevant to observe, learned Commissioner (Appeals), while determining the ALP of export commission at 5% also fell into the same error as the TPO. The determination of ALP at 5% by learned Commissioner (Appeals) is also purely on adhoc/estimate basis without following any prescribed method. It is relevant to observe, before us, the assessee has furnished material which demonstrates that since assessment year 1992-93, the assessee had been paying commission on export sales at the same rate of 12.5%. However, in none of the assessment years till assessment year 2001-02, the TPO has proposed any adjustment to the rate at which export commission was paid to the AE. It is evident, only in assessment years 2002-03 & 2003-04, the TPO has proposed adjustment. It is further relevant to observe, in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... against the aforesaid decisions of the Tribunal were not admitted by the Hon'ble High Court. Thus, he submitted, the issue is squarely covered in favour of the assessee. In addition, he relied upon the following decisions:- 1. K Ravindranathan Nair vs CIT 247 ITR 178 (SC) 2. CIT vs Foseco India Ltd 352 ITR 320 (Bom) 3. Foseco India Ltd vs ACIT ITA No.4667/M/2005 12. The learned departmental representative, though, fairly submitted that the issue is covered by the earlier decisions of the Tribunal, however, relied upon the observations of the assessing officer and learned Commissioner (Appeals). 13. We have considered rival submissions and perused materials on record. As noted by us, identical issue came up for consideration before the Tribunal in assessee's own case for assessment year 2000-01 . The Tribunal, while disposing of the appeals, both, by assessee and revenue in ITA 3703/Mum/2004 and others vide order dated 16-04-2014 has held as under:- "10.2 We have considered rival contentions and found from the record that expenditure on VRS debited and claimed in this year were duly approved by the Income Tax Department itself. Even during the relevant assessment year und ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt years 1998-99, 1999-2000, 2000-01 and 2001-02 claim of depreciation has been allowed. He submitted, the aforesaid decisions of the Tribunal have been accepted by the department and no further appeals have been filed before the Hon'ble High Court. 14. The learned departmental representative agreed with the aforesaid submissions of the assessee. 15. We have considered rival submissions and perused materials on record. It is evident, assessee's claim of depreciation on the opening WDV of block of assets has been disallowed simply for the reason that similar claim made by the assessee in preceding assessment years has been disallowed. As brought to our notice by learned senior counsel for the assessee, while deciding identical issue in assessee's own case in assessment years 1998-99 to 2001-02, the Tribunal has allowed assessee's claim of depreciation. In the latest order passed for the assessment year 2001-02 in ITA No.8978/Mum/2004 & 8746/Mum/2004 dated 28-07-2014, the Tribunal, following its earlier order, has allowed assessee's claim holding as under:- "8.1 We have considered rival contentions and found from the record that exactly similar issue has been decided by the Tribu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enior counsel for the assessee. 21. Having considered rival submissions, we find, while deciding identical issue in preceding assessment years, the Tribunal has deleted the disallowance of interest expenditure made under section 14A of the Act. In the latest order passed for the assessment year 2001-02 (supra), the Tribunal, following its earlier decisions, has deleted the disallowance under section 14A, holding as under:- "10. Ground No.5 is regarding disallowance U/S.14A. Learned AR stated that this issue has been decided by the Tribunal in assessee's own case for A.Y. 1990-91 and 1998-99 in favour of the assessee, against which the department has not filed any appeal before the High Court. Precise observation of the Tribunal for the A.Y. 1998-99 reads as under :- "22. The AO has not applied section 14A. In fact this section was not in the statute during that year. The learned CIT(Appeals) has factually analyzed the issue and has come to a conclusion that no expenditure can be attributable to the earning of tax free income. On this factual matrix, we agree with the learned counsel that the decision of the Hon'ble Bombay High Court in the case of Topstar Mercan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ultancy charges. Therefore, expenditure cannot be of capital nature. Further, he submitted, the issue is covered by the decision of the Tribunal in assessee's own case for assessment year 1999-2000. In addition, he relied upon the following decisions:- 1. CIT vs Asahi India Glass Ltd 346 ITR 329 (Del) 2. CIT VS Amway India Enterprise 346 ITR 341 (Del) 3. CIT vs Raychem RPG Ltd 346 ITR 138 (Bom) 26. The learned departmental representative fairly agreed that the issue is covered by the earlier decision of the Tribunal. 27. We have considered rival submissions in the light of decisions relied upon and perused materials on record. It is evident, the disallowance has been made on the reasoning that the expenditure incurred is of capital nature. Per contra, it is the claim of the assessee that the expenditure is not of capital nature. As we find from record, it is the claim of the assessee that the assessee had only license to use the software. It is also relevant to observe, while deciding similar issue in assessee's own case in assessment year 1999-2000 vide ITA No.4279/Mum/2004 dated 31-01-2014, the Tribunal has allowed assessee's claim, holding as under:- "2.3,2 We have per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e on account of unutilized modvat credit, it will have no impact on the profit. In this regard, he relied upon the decision of the first appellate authority in assessee's own case for assessment years 2006-07 and 2007-08. Further, he submitted, no such adjustment has been made from assessment year 2008-09 onwards. He submitted, identical issue relating to adjustment made under section 145A was decided in favour of the assessee in assessment year 1999-2000 and department has not filed any appeal against the decision of the Tribunal. In addition, he relied upon the following decisions:- 1. Hawkins Cookers Ltd vs ITO (2008) 14 DTR 206 (Mum) 2. CIT vs Mahalaxmi Glass Works (P) Ltd (2009) 318 ITR 116 32. The learned departmental representative relied upon the observations of learned Commissioner (Appeals). 33. We have considered rival submissions and perused materials on record. Apparently, identical issue relating to adjustment under section 145A of the Act came up for consideration in assessee's own case in assessment year 1999-2000 (supra). The Tribunal, while deciding the issue in the order referred to above, has restored it to the assessing officer with the following observ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by 90% for claiming deduction under section 80HHC. Noticing the above, the assessing officer called upon the assessee to explain, why 90% of the sales-tax set off, bad debts recovered and processing charges should not be reduced from the business profits for computing deduction under section 80HHC of the Act. Though, the assessee objected to the proposed disallowance; however, the assessing officer, rejecting the submissions of the assessee reduced 90% out of the income received from sales-tax set off, DEPB entitlements, bad debts and processing fee by resorting to of Explanation (baa) of section 80HHC while computing deduction under the said provision. Assessee contested the aforesaid decision of the assessing officer before learned Commissioner (Appeals). After considering the submissions of the assessee in the context of facts and materials on record as well as the extant statutory provision, learned Commissioner (Appeals) upheld the decision of the assessing officer with regard to sales-tax set off, bad debts and processing charges. Insofar as DEPB entitlement is concerned, learned Commissioner (Appeals) held that the assessee would only be entitled to include the value of DEP ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... greed with the assessee that DEPB entitlement does not come within the ambit of Explanation (baa); however, he has erroneously held that the assessee would be entitled to claim such deduction only on the DEPB entitlement received and utilized during the year. Thus, he submitted, since the receipt from DEPB entitlement is not covered under Explanation (baa) to section 80HHC of the Act, 90% of such receipts cannot be reduced for computing deduction under section 80HHC of the act. In support of such contention, he relied upon a decision of the Hon'ble Supreme Court in case of Topman Exports vs CIT 342 ITR 49 (SC) and the decisions of the Tribunal in assessee's own case in assessment years 2000-01 and 2001-02. 39. The learned departmental representative, on the other hand, strongly relied upon the observations of the assessing officer and submitted that disallowance made by the assessing officer should be restored. 40. We have considered rival submissions in the light of decisions relied upon and perused materials on record. Insofar as availability of deduction under section 80HHC of the Act on sales-tax set off is concerned, it is noticed, while deciding identical issue in assessee' ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... und has been specifically considered by the Hon'ble High Court in case of Dresser Rand (supra) respectfully following the said decision, we hold that sales tax refund and set off will be considered for reduction as per Explanation (baa). Further, the alternate claim of the assessee that only the net receipt should be considered for reduction as per Explanation (baa) is covered by the judgement of Hon'ble Supreme Court in case of ACG Associated Capsules P. Ltd. v. CIT (343 ITR 89). We therefore direct the Assessing Officer only the net receipt after deducting expenditure incurred for earning of such income, will be considered for reduction as per Explanation (baa)." 11.1 in view of the above, the issue with regard to allowing claim of deduction in respect of sales tax set off and refund, the assessee is not eligible in view of Explanation (baa) to Section 80HHC. Accordingly, we dismiss this ground of assessee's appeal and direct the AO to reduce the amount of sales tax refund from the eligible profit for computing claim of deduction u/s.80HHC." 41. The same view was reiterated by the Tribunal while deciding assessee's appeal in assessment year 2001-02 (supra). Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch the said provision has ceased to be a code by itself. In the above formula there existed four variables, namely, business profits, export turnover, total turnover and 90% of the sums referred to in clause (baa) to the said Explanation, in the computation of deduction under Section 80HHC ail four variables had to be taken into account. All four variables were required to be given weightage. The substitution of Section SOHHC(3) secures profits derived from the exports of eligible goods. Therefore, if all the four variables are kept in mind, it becomes dear that every receipt is not income and every income would not necessarily include element of export turnover. This aspect needs 10 be kept in mind while interpreting clause (baa) to the said Explanation, The said clause stated that 90% of incentive profits or receipts by way of brokerage, commission, interest, rent, charges or any other receipt of like nature included in Business Profits, had to be deducted from Business Profits computed in. terms of Sections 28 to 44D of the I. T. Act. In other words, receipts constituting independent income having no nexus with exports were required to be reduced from Business Profits under clau ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... king out the formula under Section 80HHC(3) of the I. T. Act and while applying the four variables one has to ascertain whether the receipt has an attribute of export turnover. An indirect tax like excise duty does not have that element of export turnover as understood in the above formula. As stated above, it is recovered by the taxpayer on behalf of the government Therefore, in the present cases, our judgment in Commissioner of Income Tax. Cotmhatore v. M/s. Lakshmi Machins Works - 2007(6) Scale 168, has no application. 24. Accordingly, the impugned judgments of the High Court and the Tribunal are set aside and the above civil appeals filed by the Department are accordingly allowed with no order as to costs. 17.1 This issue has been discussed by us at para 11.2 hereinabove, accordingly the AO to recompute the deduction u/s.80HHC after excluding the net income from processing charges. However, bad debts recovered is neither part of totai turnover nor export turnover for the purpose of Section 80HHC, therefore, same is required to be excluded from eligible profit for the purpose of clause (baa)." Respectfully following the aforesaid observations of the co-ordinate Bench, we ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2000-01 (supra), the Tribunal has directed the assessing officer to compute deduction on DEPB license by following the ratio laid down by the Hon'ble Supreme Court in case of Topman Exports vs CIT (supra). For better appreciation, the observations of the Tribunal in this regard are reproduced below:- "19. Ground No.(vii) is regarding directing the AO to calculate deduction u/s.80HHC without reducing 90% of the DEPB license sold without appreciating the facts of the case. This issue has been decided in favour of the assessee by the decision of Hon'ble Supreme Court in the case of Topman Exports Vs. CIT, 342 ITR 49 (SC), wherein the Hon'ble Supreme Court has held as under :- The aforesaid discussion would show that where an assessee has an export turnover exceeding ₹ 10 crores and has made profits on transfer of DEPB under clause (d) of section 28, he would not get the benefit of addition to export profits under third or fourth proviso to sub-section (3) of section 80HHC, but he would get the benefit of exclusion of a smaller figure from "profits of the business* under Explanation (baa) to section 80HHC of the Act and there is - , nothing in Explanation (baa) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... On a careful perusal of the observations of the Tribunal reproduced above, it appears that the Tribunal has proceeded on the basis that the income claimed as deduction under section 80HHC of the Act arises out of sale of DEPB license. However, before us, it is the specific contention of the learned senior counsel for the assessee that DEPB entitlement has not arisen out of sale of DEPB license, but has accrued as income to the assessee. On a reading of the impugned assessment order as well as the order passed by the learned Commissioner (Appeals), prima facie, we are of the view that various facts relating to the issue either have not been properly placed before the departmental authorities or have not been properly appreciated by them. At the cost of re-iteration, we may observe that in the submissions made before the assessing officer, the assessee itself has stated that DEPB entitlement is akin to cash assistance; hence, covered under section 28(iiib). In that event, certainly it would be covered under Explanation (baa) to section 80HHC. However, assessee's alternative claim that it can still avail deduction under proviso to section 80HHC(3) requires consideration and which, a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the only reason for disallowance of assessee's claim is, the assessee has not proved that the debt is not recoverable. He submitted, as per the amended provisions of section 36(1)(vii), there is no requirement for the assessee to prove that the debt has become bad and not recoverable. He submitted, once the debt is written off in the books of account, it has to be allowed. In support, learned senior counsel relied upon the following decisions:- i. TRF Ltd vs CIT (2010) 323 ITR 397 (SC) ii. ACIT vs Glaxo Smithkline Pharmaceuticals Ltd ITA No.6444/Mum/2007, dt 28-01-2011 51. The learned departmental representative relied upon the observations of the assessing officer. 52. We have considered rival submissions in the light of decisions relied upon and perused the materials on record. As per the amended provision of section 36(1)(vii) of the Act, any bad debt written off in the books of account as irrecoverable is an allowable deduction. The effect of the aforesaid statutory provision has been lucidly explained by the Hon'ble Apex Court in case of TRF Ltd vs CIT (supra). Therefore, once the conditions of section 36(1)(vii) are fulfilled, assessee's claim has to be allowed. Keepi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... very same issue has already been decided by the Tribunal in assessee's own case in terms discussed above. After considering the decision of Hon'ble Supreme Court, the Tribunal has concluded that gross annual ratable value of the property for the purposes of computation of house property income is to be determined at the annual value determined by Municipal Corporation. As the facts and circumstances during the year under consideration are same, hence, respectfully following the decision of the Tribunal, we direct the AO to determine ALV at the value determined by Municipal Corporation for the year under consideration. Hence, this ground of the assessee is allowed for statistical purposes, whereas the ground raised by the Revenue is dismissed." 58. In view of the aforesaid, we uphold the decision of learned Commissioner (Appeals) by dismissing the ground raised. 59. In ground 2, department has challenged partial relief granted by learned Commissioner (Appeals) in respect of adjustment made to ALP of export commission paid. This ground is corresponding to ground 1 of assessee's appeal in ITA No.3092/Mum/2006, decided by us in the earlier part of the order. In view of our de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... resaid, we uphold the decision of learned Commissioner (Appeals) on the issue. 65. As regards set off of sales-tax refund, while deciding corresponding issue raised in ground 7(a) of assessee's appeal in ITA No.3092/Mum/2016, we have followed the decision of the Tribunal in assessee's own case for assessment year 2000-01, wherein, it is held that sales tax set off and refund are not eligible for deduction in view of Explanation (baa) to section 80HHC. Therefore, 90% of such receipt has to be excluded from the business profits as well as turnover for computing deduction under section 80HHC of the Act. Our decision therein will apply to this ground as well. 66. As regards receipts from sale of scrap, we uphold the decision of Learned Commissioner (Appeals). 67. In ground 7, the revenue has challenged the decision of learned Commissioner (Appeals) in deleting the disallowance on account of provision for impairment of assets written back while computing deduction under section 80HHC. 68. We have considered rival submissions and perused materials on record. We find, the write back of provisions for impairment has already been reduced in the computation of total income by the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ready reference, we quote sec 80HHC(3)(b) and clause (e) of Explanation as under: [(3) For the purposes of sub-section (1) - (a)...................... : (b) where the export out of India is of trading goods, the profits ' derived from such export shall be the export tumover45 in respect of such trading goods as reduced by the direct costs and indirect costs attributable to such export; (c)............ , Explanation.-For the purposes of this sub-section,- (a).................... (b) .................. (d) (e)"indirect costs" means costs, not being direct costs, allocated in ratio of the export turnover in respect of trading goods to the total turnover; (f).............. ; 10.2 It is clear from the combined reading of sub. Sec. 3(b) and clause (e) of explanation to sec. 80HHC(3) that the profit derived from export of trading goods shall be the export turnover of trading goods minus direct cost and indirect cost attributable to such exports. The indirect cost has been defined under clause (e) of Explanation which means the indirect cost which is not direct cost and allocated in the ratio of export of trading goods to the total turnover. 10.3 The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the assesses would be entitled to raise a new ground, provided it is a ground of law and does not necessitate any other evidence to be recorded, the nature of which would not only be a defence to the appeal itself, but may also affect the validity of the entire assessment proceedings. If the ground succeeds, the only result would be that the appeal would fail. The acceptance of the ground would show that the entire assessment proceedings were invalid, but yet the Tribunal which hears that appeal would have no power to disturb or to set aside the order in favour of the appellant against which the appeal has been filed. The ground would serve only as a weapon of defence against the appeal, if the respondent has not himself taken any proceedings to challenge the order in appeal, the Tribunal cannot set aside the order appealed against. That order would stand and would have full effect in so far as it is against the respondent. The Tribunal refused to allow the assesses to take up this ground under an incorrect impression of taw that if the point was allowed to be urged and succeeded, the Tribunal would have not only to dismiss the appeal, but also to set aside the entire assessm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing separate procurement and export divisions, while the involvement of branch office at Mumbai can be ruled out with a specific office for the purpose located therein, in respect of the branch office at Hyderabad, the other place for procurement, the same cannot be accepted. Hence the expenditure incurred at Hyderabad branch office to the extent not directly related to domestic sales is also required to be taken as part of the indirect cost for working out deduction under section 80 HHC (3)(b) of the Act, The Assessing Officer shall rework out the indirect cost under the section accordingly." x x x x x x 10.10 As we have already discussed that for the purpose of sec. 80HHC(3}(b) r.w.clause (e) of Explanation, the indirect cost to be allocated in the ratio of export turnover of trading goods to the total turnover has to be taken as the total figure of the indirect cost incurred for the total turnover and not the indirect cost directly related to the export turnover as held by the C!T(A). X X X X X X X 10.12 It is clear from the working of the Assessing Officer that for determining the indirect cost, the AO has reduced from the total cost of business, cost of goods as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s challenged the deletion of penalty imposed under section 271(1)(c) of the Act. 80. Briefly the facts are, while completing the assessment for the impugned assessment year, the assessing officer made various additions and disallowances. Out of such additions/disallowances, the assessing officer initiated proceedings for imposition of penalty under section 271(1)(c) of the Act alleging concealment of income on the following additions:- A. Software Expenditure - ₹ 12,27,147/- B. Depreciation on obsolete assets - ₹ 55,54,998/- C. VRS expenses - ₹ 8,24,60,028/- D. Bad debts - ₹ 26,41,568/- E. Transfer Pricing Adjustment - ₹ 6,67,71,476/- Total - ₹ 15,87,58,217/- 81. In response to show cause notice issued under section 274 r.w.s. 271(1)(c) of the Act, though, the assessee furnished its explanation stating that neither there is furnishing of inaccurate particulars of income nor concealment of income, however, the assessing officer rejecting the explanation of the assessee imposed penalty of ₹ 5,66,06,683/-. Against the order so passed, assessee preferred appeal before learned Commissioner (Appeals). Co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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