9911796707
TMI Blog1986 (4) TMI 101X X X X Extracts X X X X X X X X Extracts X X X X ..... asst. yr. 1981-82, uncalled for additions were made by the ITO in assessment proceedings and though the same are deleted by the CIT (A) after considering the merit, these appeals were disposed of when assessment for 1982-83 was underway. It was also mentioned therein that while framing the assessment for 1982-83, earlier order of the CIT(A) and still earlier order the CIT(A) was ignored on the plea that the Department did not accept the same and had filed second appeals. It was mentioned therein that the ITO adopted the same strategy as done by his predecessor for making additions notwithstanding the clear finding of the first appellant authority in favour of the assessee. It was also submitted therein that since the relief granted by the CIT(A) has not been tested before the Tribunal for these years, as the Revenue was in second appeals, the ITO made heavy additions for 1982-83 and created a demand of Rs. 35 lakh or so. 2. Normally out of turn requests are made in appeals where heavy demands are pending but here though the assessee had obtained relief from the CIT(A) substantially for all the years, in order to avoid repetition of the same in subsequent years, they came in an a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th Nov., 1984. 2. That I at the time of hearing of appeals for the above assessment year, was posted as ITO CC v, ld, and was in no way connected with the above quoted case, which was under the charge of the ITO, CC VI, Shri V.K. Singal. 3. That I was not present at the time of hearing of the appeals for the above assessment year and as such did not argue the case on behalf of the Department." Identical affidavit was also filed for subsequent assessment years, with which were are not concerned here. Copy of the said affidavit had been handed over to the authorised representative of the assessee who, however, prayed that a photostat copy of the same also be sent to the CIT(A) for comments. There were many grounds raised in these two cross-appeals but the main ground was in the Revenue's appeal regarding opportunity, being the first ground saying that; "The ld. CIT(A) has erred both in law and on facts in denying adequate opportunity to the Departmental Representative of being heard. the ITO was not even informed about the fixation of the appeals by the CIT(A), meaning thereby that the Department was deprived of its legitimate right of representation." 4. Subsequently ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... refer to this office correspondence on the above noted subject. An affidavit of Sh. S.R. Chhabra, ITO, was filed for above said years as a part of evidence that no opportunity was provided to the Department may kindly be withdrawn and the original grounds of appeal remains the same as per communicated in the grounds of appeal." Copy forwarded to the: 1. IAC, Range II (Central) for information., 2. CIT, Central, Ludhiana, for information. As directed by him, the affidavit of Sh. S.R. Chhabra has been withdrawn." With this, seriousness of the matter got mitigated to a considerable extend but the ld. Senior Departmental Representative pressed the Revenue's first ground and addressed us on the same vehemently. The said appeals were heard at length on 24th Feb., 1986, 25th Feb., 1986 26th Feb., 1986 and hearing was concluded on 3rd March, 1986. 8. We could conveniently deal with the assessee's appeal first because the issues involved therein are small and mostly covered or not pressed but for the sake of continuity and clearer understanding regarding the issue of opportunity, first we elect to deal with the first ground in the Revenue's appeal pertaining to opportunit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Kuthilal vs. CIT (1960) 38 ITR 1 (PB). 9. The ld. counsel for the assessee, on the other hand, on the issue of opportunity submitted and exclaimed as to what kind of opportunity has been denied to the Revenue—whether that of hearing, producing further evidence, or prolonging the arguments to unlimited extent. He submitted that there is no hard and fast rule so far as opportunity is concerned and in the instant case, hearing continued for two years or so. He submitted that Sh. Chhabra presented himself upto 9th March, 1984 when hearing of these appeals were concluded and it was marked 'for orders' But as ill-luck would have it, instead of final order, there came a remand order. He submitted that in the course of remand report, additional evidence relied upon by the Revenue after the assessment was framed, was put to the assessee, which was most unjust and illegal. It was after thorough shaking of the assessee by the ITO that remand report was given to the CIT(A) who handed over the same to representative of the assessee on 27th Oct., 1984 and got their comments on 5th Nov., 1984. On 5th Nov., 1984 according tot he ld. counsel for the assessee and as per entries in the order-shee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... challenge the admission of the additional evidence placed by the Revenue and specially so when he is acting as representative for the respondent so far as issue of opportunity is concerned. In reply, the ld. counsel for the assessee submitted that he is not challenging the remand part as such now. All that he is doing is only to tell the Tribunal that evidence collected by the ITO, admitted by the CIT(A) and utilised by him for remand purpose, was all illegal though under s. 250(4) the CIT(A) can make enquiry as he things fit. There is no such rights granted to the ITO. He submitted that the CIT(A) misplaced his reliance on Omar Salay Mohamed Sait vs. CIT (1959) 37 ITR 151(SC). He submitted that rule of justice is for the subject and not for the Department. He went at length through para 40 of the CIT(A)'s order and submitted that identical evidence had been before him and it was very same paperbook covering 103 pages which was rejected by the Tribunal in 1976-77 appeals, which was admitted by the CIT(A), and the case instead of disposing of finally, he elected to pass a remand order 11. Since hearing on the issue of opportunity itself went on for hours and the issue was not onl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Revenue. Subsequently to many a dates, adjournments were granted. The ITO framing the assessment was one Sh. G.N. Srivastave of Cabinet Committee V1 but w.e.f. 1st Sept., 1983 he was succeeded by Sh. G.R. Chhabra, who exercised the jurisdiction over the said case upto 17th Aug., 1984 when the case was transferred to CCV1 the ITO in charge of which was Mr. V.K. Singal, who succeeded by Sh. Manikchand. He drew our attention to the photostat copy of the order-sheet. While reading out the written argument, he has mentioned that Sh. Chhabra appeared on 14th Sept., 1983 before the CIT(A), gave the written comments, and again on 16th Nov., 1983 it was Sh. Chhabra who filed the written note. Again on 16th Dec., 1983 it was Sh. Chhabra who argued certain grounds No. 17 in particular Sh. Chaabra again appeared on 18th Jan., 1984, 13th Feb., 1984 and 9th March, 1984 and on the ticklish ground (No. 18) he had completed his arguments. It was actually on 9th March, 1984 when the appeals was heard finally and marked 'for orders' but to the misfortune of the assessee, the order of the CIT (A) culminated in an order remaining the case to the ITO, not only for the year under consideration but also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was left by his predecessor and further right is given to the assessee only that he may demand an opportunity before any final order is passed. No such right is available to the Revenue. Regarding the adequacy of opportunity it is mentioned that the ITO, CC VI held the jurisdiction over the case on 17th Aug., 1984 appeared before the CIT several dates made oral as well as written on submissions, the appeal was marked finally for orders but resulted in an order of remand. He quoted the expression "before disposing of any appeal" and "may direct the ITO to make further enquiry and report the result of the same" and according to him, it makes it clear that the ITO is only to communicate in his report the result of the enquiry made by him. As per his submission, it is only the assessee who alone is to in to get communication of the order in the form of remand report from the ITO thought the CIT(A) and making submissions in respect thereof. It is further mentioned that despite this, the Revenue was granted as opportunity and the CIT (Admn) deputed Sh. Chhabra with the ITO in charge of the case who represents both on 5th Nov., 1984 and 6th Nov., 1984. This is apparent from the order-she ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... atives of the assessee and Ahri Chhabra were present and copy of the ITO's comments was handed over to the authorised representative of the assessee. Again a reply was filed by the representatives of the assessee on 16th Nov., 1983 regarding interest unders.214 whereas the ITO filed written note regarding admissibility of fresh evidence though a brief note against admission of evidence was filed as per order-sheet entry dt. 16th Nov., 1983 but as the assessee wanted further time the case was adjourned to 16th Dec., 1983 on 16th Dec., 1983 again a latter dt 14th Dec., 1983 challenging the admission of fresh evidence was filed by the assessee's counsel and here the ITO addressed his arguments on ground no 17 to clarify certain points, as noted by him. it was mentioned in the said order-sheet entry that arguments on ground no 18 are still to be given and the case was adjourned to 18th Jan., 1984. On 18th Jan., 1984 the assessee was represented by his counsel and the Revenue by Shri Chhabra and on the request of the assessee's counsel the case was adjourned because the Tribunal's decision on the admission of additional evidence pertaining to asst. yr. 1976-77 was expected shorly. On 13 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng the same, he mentioned that ground to that effect may remain the same and be adjudicated on merit. Against the said affidavit of Shri Ahhabra. Gist of which we have given above after withdrawal and presence of affidavit after withdrawal and presence of affidavit from Shri Dinesh Gogna, representative of the assessee, on the one hand and letter of the CIT on the other hand, and order-sheet entries right form start upto the date when appeals was heard finally, indicate that full opportunity was granted to the ITO. As a matter of fact, war of words, if permitted to be continued, the CIT(A) permitted, can never result in adjudication on any issue. If there are two parties, one argues the case first the second one replies and the original party is granted an opportunity in rejoinder, perusal of the length order-sheet shows that rules and counter-rules, comments and counter-comments, submissions and counter submissions and further counter written submissions have been permitted which cast really a confusion. 15. We would have ordinarily concluded this issue in a few words also but since, as observed by as observed by us above, it is a exceptional type of dispute which is raised by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ative instructions these appeals had to be decided on priority basis, as enough opportunity has already been granted to both the parties." On the above depositions and other depositions in the said affidavit, Shri gogna who was present in the Court was questioned who admitted his affidavit and the ld. departmental representative even on asking of the bench for cross-examination, of Shri Singal submitted that in this regard he has already filed a letter from Shri Singal. Looking to the order-sheet, subsequent withdrawal of affidavit of Shri chhabra, latter from CIT(A) and affidavit of Shri gogna we are unable to hold that opportunity was not granted to the Revenue. 16. Even for the sake of argument, if it is admitted that after additional evidence was placed by the Revenue before the CIT(A), both the parties dealt with the same before him in their own respective way and the matter went in to the ITO who at length questioned the assessee in respect of all the issue of bogus purchase of oil in which addition was assailed by the CIT(A) in ground No.17 that of Rs. 3,75,926 on account of M/s Nacrang Co., M/s Tilak Ram Dharam pal and M/s Mohinderaoil general Mills. And in respect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was regarding grand of opportunity to the assessee and to the Revenue. Thus case was relied upon on the ld./senior departmental representative on the issue of undue haste. It was observed in the said case that there was ample materiel to show that the ITO made the assessment in undue hurry. The facts of the instant case are absolutely in reverse. The CIT(A) took three years in disposing of the appeals granted more than twenty opportunities to the assessee and the Revenue and on more than a dozen occasions had written arguments from both of them, so much so 103 pages of voluminous evidence which was collected by the Revenue after assessment was framed, was not only accepted as additional evidence by the CIT(A) but he dealt with the same on merit after remanding the matter to the ITO. It cannot be said that the instant case was disposed of in any hurry or haste. The Punjab high Court decision in the case of Mangat Ram Kuthiala, the finding on which reliance could be placed by the ld. Senior Department representative was that: "........ the hearing of the parties in an appeal by the Tribunal under s. 334 of the IT Act was imperative and if a party could establish that it was never ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by limitation." In respect of this ground, the ld. counsel for the assessee was fair enough to admit for that this stands adjudicated against the assessee as per para 7 of our earlier decision pertaining to asst. yr. 1976-77. He neither elected to withdraw the same nor he could say anything in respect of his contention. For the very same reasons given by us in our earlier order dt 21st Jan.,1984 in I.T.A.Nos.168 etc/Chandi? 1980, this ground in the assessee's appeals is rejected. (Para 19 to 30 are deleted as contents therefore are not very relevant to the main issue-Ed.) 31. Now what survives for our consideration are rest of the grounds raised by the Revenue in its appeal, excluding that pertaining to opportunity which we have disposed of against the Revenue in earlier part of this order. The second ground is in respect of s.80j relief in respect of five units without deducting liabilities. The ld. sr. Departmental representative Mr. R.K. Bali in this regard submitted that after the supreme Court decision issue is covered against the assessee. However, he was fair enough to admit that the order of the CIT(A) on this issue stands rectified vide his order under s. 154 (No ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the CIT(A) who after admitted the same, remanded the matter and yet adjudicated the issue against the Revenue. This is dealt with by the ITO at length is paras 54 onwards of his order, that submitted that the CIT(A) has only gone on the premise that money was credited in the bank accounts of these parties and there were certain statements. He submitted that in one of the cases, even the party made an unequivocal statement before the ADI. He submitted that in the cases of M/s Tilak Ram Dharam pal and Punjab sales corporation though there was no statement before the A.D. but there were statement which go against the assessee and in favour of the Revenue. He was however, fair enough to say that in the statement of M/s Mohinder oil general Mills there was nothing against the assessee but these are exactly same type of sales in respect of which settlements have been entered into by other parties. 34. The ld. counsel for the assessee Mr. G.G Sharma submitted that in these grounds (5 to 7) the allegation of the Revenue has been that quality of oil stands described wrongly by the assessee. He submitted that absolutely identical issue had been before the Tribunal for asst. yr. 1976-77 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent was framed and placed before the CIT(A) as consequence of which there came an order from his remanding the case to the ITO and in those proceedings all the evidence was considered the assessee may have no case. But again Mr. Sharma said that this is a case which has been handled by the Revenue very shabbily and it could resort to s. 147(A) proceedings if there was information It was the ITO who enjoyed power of remand He submitted that against that, as per s. 250(4) the first appellate authority can make enquiry as he thinks fit. There is no right given by the stature to the ITO under the Act, Then he goes through the remand report which is available on the paper book. He submitted, at the cost of repetition that rule of justice is for the subject. He reads out para 40 onwards of the CIT(A) order pertaining to asst. yr. 1976-77 and pages 23 to 27. 36. Since it was this addition which was the subject matter of remand being ground the No. 17 before the CIT(A) there were other additions which were disputed before the CIT(A) in ground No. 18. In sum of Rs. 18,40,084 made by ITO an account of doubtful purchases but sustaining the addition on low yield basis This dispute is raised ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or asst. yr. 1976-77. In that assessment year, supplies from eight parties were doubted and an addition on account of inflation of purchase was made by the ITO to the extent of Rs. 11,13,648, which was deleted by the Tribunal and as such order was accepted by the Revenue and even s. 256(1) application was not moved by the Revenue. The assessee has been manufacturing vanaspati and for that purpose purchased various kinds of oils which are used in the manufacture of vanaspathi. As a consequence of certain statements recorded by the ADI (Intelligence), the ITO thought that the assessee mill like other vanaspati manufacturers of Ludhiana had been getting bogus purchase bills in respect of edible oil used as raw material in the manufacture of vanaspati with the ulterior motive of increasing the cost of production and thereby reducing the profit. According to the ITO, the assessee used cheaper oil such as mustard oil Taramira oil and groundnut oil, which were actually prohibited, but in respect of the said oil the assessee obtained bills from intermediaries showing consumption of other oil which are having higher price such as tili oil, Niger seed oil, maize oil, soybean oil, sunflower o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stance of the assessee with partly sum of Rs. 100 or so and huge amounts which were deposited by them in their respective accounts, said to be recoveries from the assessee, were simultaneously withdrawn with a difference of a day or two. It were these amounts which were related with the bogus dealings of oil from intermediaries with the assessee. He even submitted that these intermediaries were introduced to the bank by the persons having intimate relation with the assessee. He attempted to make big capital out of the fact that these accounts were closed immediately after the dealing of the respective people were over with the assessee. He submitted that those intermediaries who were examined by the ADI between February and June, 1978, had accepted their involvement in the scandal and some of them even named the assessee-company as one of the persons who also indulged in change of description of oil. 40. On the interjection of the ld. counsel for the assessee Mr. Sharma that hardly one party made a statement in the instant case before the ADI and that too was withdrawn subsequently in a statement recorded by the ITO, the ld. Senior departmental representative Mr. Bali submitted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve that there was not inflation of purchases. He further went on to assert that the CIT(A) was absolutely unjustified in placing reliance on the decision of this Bench in the assessee's own case for the asst. yr. 1976-77. Due to distinction in facts, as above said, according to him, Mr. Dharam Pal Garg and Mr. Jagdish Chander of M/s Tilakram Dharampal and Punjab Sales Corporation were examined in the presence of the assessee, when they clearly implicated the assessee in the oil scandal. The assessee, according to MR. Bali, did not elect to produce any person from M/s Navrang Co. M/s. Mohinder Oil and General Mills, traders and other suppliers of oil even during the assessment proceedings. Therefore, according to him, the addition in respect of inflation of purchase price of oil in Vanaspati unit and purchase of rice bran in the Solvent unit deleted by the CIT(A) was unjustified. [Paras 42 and 43 are deleted as they are not very important to the main issue—Ed.] 44. The ld. counsel for the assessee Mr. G.C. Sharma actively assisted by Mr. Kawal Krishan, Mr. Dinesh Gogna, Mr. Amarjit Singh and Mr. Sharma, another young advocate, addressed us at length regarding admission of ad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are unable to accept the contention of Mr. Sharma that fresh evidence subsequently collected by the ITO and produced before the CIT(A) should have been ignored. Mr. Sharma, therefore, then came to address us on merit, synopsis of which stands given in the earlier part of the order. According to Mr. Sharma, these additions were exactly like those which stands deleted by us for asst. yr. 1976-77. 46. Regarding notoriety and scheme of things, he submitted that nothing can turn on that and burden to prove that lay on the Department. He relied on our earlier decision in the assessee's own case M/s Oswal Woolen Mills Ltd. I.T.A. No. 168 etc. Decided on 21st Jan., 1984, and submitted that the Tribunal in that order observed that strong evidence was required to prove that the assessee was in contravention of law. He relied on certain excerpts of our order available at pages 32 and 33. He submitted that the issue pertaining to settle by other parties was also before the Tribunal in the immediately preceding year in which observation of the Tribunal which are available at page 26, stand accepted by the Revenue as no reference was sought in respect of said order. 47. Regarding reliance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xcise Department were also produced. 51. After taking into consideration the rival submissions and voluminous paper books filed by both the sides and on the basis of our earlier order in ITA No. 168 ect. which stands duly accepted by the Revenue and order of the CIT(A) for asst. yr. 1976-77 which stands confirmed by us and his order for the year under consideration, we are unable to interfere in the finding of the CIT(A). On the one hand, as per revenue, we have certain statements from the alleged intermediaries. Regarding the statement of Subhash Chander before the ADI, it was withdrawn subsequently through an affidavit and even in the course of examination, he reiterated the very same stand in support of the assessee. In other words, affidavit and statement of Subhash Chandeer since subsequently go against the Revenue. Statement in Punjab Sales Corpn. That of Jagdish Chander is in the course of remand proceedings. Perusal of entire evidence in this respect only shows that these intermediaries are nothing but persons of unscrupulous nature and only say what suit them, as it different stages they have been stating differently. On the other hand, they have issued bills under thei ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion in favour of the illegality of a transaction, in fact the presumption was the other way about. There must be evidence to show that the assessee did sell goods in excess of the legally fixed rates.' It is correctly placed. Such decisious can be multiplied" Again at pages 39 and 40 of the very same order, the Tribunal has evaluated the evidence given by the assessee in the following words: "In view of the overwhelming evidence adduced by the assessee, which stand corroborated by its books of a/c, stock registers, bills and even by sale of finished goods made by him and its closing stock, as per which record, which is maintained by the assessee in regular course of business and which are periodically checked by the Excise Department and other Govt. Authorities, who did not find any discrepancy in record, we are of the view that the assessee has discharged its burden and proved that: (i) the purchase of oil was of kind and quality/quantity and was for the same value as mentioned in the books of a/c of the assessee for which they had made payments to the parties who issued bills for same, (ii) a mere assertion by suppliers before the ADI or other authorities that they ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Corpn. We must be given the complete details of the alleged bonus profit distributed by them in the form already requested. (iii) We must be given the names of the brokers through whom both the parties and ADI allege that the transactions with us were finalised in respect of each transaction." Even the books of account were required to be checked and Abhey Kumar Oswal was requested to be summoned under s. 131. Statements of all the parties are so lengthy that it seems that questions had been put purposelessly. Before us, Besides the books of account, statutory stock registers maintained by the assessee in the normal course of business were produced, which were kept as per requirement of the Central Excise Department and Directorate of VOP. These registers had been checked by the authorities from time to time. The assessee has proved and we have found it as a fact that samples were also drawn from various kinds of raw material in stores for production of vanaspati. Samples were also drawn from the vanaspati manufactured by the assessee-company. With the production of these registers in original, the assessee gave photostat copies from the registers in proof of the stores chec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t., 1977, 29th Nov., 1977 and 30th Jan., 1978. 6. Statutory stock-cum-process register of cotton seed oil for 1976-77 and 1977-78 verified by Sh. S.P. Gupta Inspector Directorate of VOP on 26th June, 1976, 28th Aug., 1976, 29th Sept., 1976, 19th Oct., 1976, 26th Nov., 1976, 30th Dec., 1976, 26th March, 1977 and 31st March, 1977. All these details were also shown to the ld. Sr. Departmental representative Mr. Bali, who though could not deny the authenticity of the same but went on reiterating his submissions regarding the statements of certain intermediaries, about whom we have already remarked that they are not only unscrupulous but have resorted to giving statements, bills, vouchers, affidavit as suited them. It can be will-realised as to what is the worth of the statement given before the ADI or anyone else subsequently against the assessee and without showing the books of account. In the light of above discussion and because of overwhelming documentary evidence available with the assessee, simply because there has been scandal in the trade and some people have gone into settlement, the assessee should not be made to suffer on the strength of suspicion howsoever strong may ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tock registers which were examined by the parties and no discrepancy as such was found in the same. The yield of rice bran oil achieved during the year under consideration was 11.72 per cent as against 11.73 per cent achieved in the immediately preceding year. Comparative chart was filed by the assessee on its compilation right from 1975-76 to 1978-79 assessment years. Undoubtedly in earlier years, at one stage the yield had been higher. The ITO worked out month-wise yield and observed the same to be low. Since the issue pertaining to yield had been before as for asst. yr. 1976-77, on that very basis the ld. counsel for the assessee was required to furnish a chart. In the earlier year, yield of rice bran alone was calculated by presuming the yield of rise husk at the constant rate of 4 per cent. From the said comparative chart, we find that the yield for the year under consideration is in conformity with second period pertaining to asst. yr. 1976-77. When we peruse the month-wise yield worked out by the ITO at page 35 of his order, we find, it does differ but, as submitted by the ld. counsel for the assessee, yield would be different on many considerations such as equality of rice ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... In the case of M/s Lal Oil and General Mills to which the CIT(A) had also referred in para 13 of his order, referred to by us in ITA NO. 276, the CIT(A) had gone in depth in analysing the yield of rice bran oil and husking in about 16 full-scap pages. He had compared the results of about 8/10 oil producing mills in Punjab and after entering into detailed discussion, had deleted the addition of more than Rs. 14 lakh in the trading account of M/s Lal Oil and General Mills, which was found to be an identical case, when referred to by us in ITA No. 276. On the basis of our observations made in the above said case and on the strength of comparative chart where yield in the immediately preceding year was 11.73 per cent which was accepted by us, yield is 11.74 per cent for the year under consideration and the CIT(A) had accepted the yield disclosed by the assessee as justified and addition as a consequence of application of 15.61 per cent by the ITO was rightly deleted. In view of the additional evidence adduced and the record maintained by the assessee, actual yield of oil achieved by it and for our decision on this issue for asst. yr. 1976-77, we hold that the CIT(A) was amply justifie ..... X X X X Extracts X X X X X X X X Extracts X X X X
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