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2022 (6) TMI 943

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..... ngs, at the same time, it is the matter of record that the assessee has duly filed the copy of the partnership deed, with the return of income for A.Y. 2006 07 and which is available as part of the assessment records with the Assessing Officer. Given the statement of the ld. AR at the Bar that there has been no change in the constitution or contents of the partnership deed and taking into account, .....

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..... g to A.Y. 2008 09. 2. At the outset, it is noted that there is a delay of 55 days in filing the present appeal. After considering the affidavit filed by the assessee and hearing both the parties, the delay in filing appeal is hereby condoned and the appeal is admitted for adjudication. 3. During the course of hearing, the ld. AR submitted that the sole reason for disallowance of partner s .....

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..... the disallowance so made by the Assessing Officer and confirmed by the ld.CIT(A), we directed to be deleted. 4. Per contra, the ld. DR has relied on the order of the lower authorities. 5. After hearing both the parties and perusing the material available on record, we find that the sole reason for disallowance of the partner s remuneration as well as interest on partner s capital is on accou .....

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