Friday, 25 September 2015
Notice u/148 issued to address in PAN data base which is no longer occupied by assessee. Assessee not precluded from pleading that notice served to wrong address. Also even if assessee participates in reassessment proceedings , the Jurisdictional defect does not get cured.IN THE HIGH COURT OF DELHI AT NEW DELHI 2. + ITA 665/2015 ATLANTA CAPITAL PVT. LTD.
Matters which are not covered by notified standards u/s 145(2) and are also not covered by provisions of income tax law can be interpreted as per non notified standards or guidance notes of ICAI although not mandatory in nature- Held by AP High Court in Pact Securities on 05-02-2015 ITA 252/2003. The Court allowed deduction of lease equalization charges as per Guidance Note issued by ICAI applicable before 01-04-2001
Refund of excess salary which was granted in earlier years is deductible because the assessee is under legal obligation to repay the amount. Ahmadabad Trib. lays down that salary “due” and not salary “accrued” or “arising” is sought to be taxed u/s 15. The legislature has intentionally used the words “due” and not “accrued”. -Vrajeshwari B. Parikh 15-09-2015 ITA 1512/2014
Section 40(a)(ia) 2nd Proviso Inserted by Finance Act wef AY 2013-14 abating TDS disallowance on production of CA certificate attesting payment of tax and filing of return by deductee which was held applicable with retrospective effect by Agra Bench in Rajiv Kumar Agarwal ITA PGB/2013 and confirmed by ITAT Delhi in Ansal Land Mark Township P Ltd also upheld by Delhi High court in ITA 161/2015 dated 26-08-2015. High Court praised ITAT for thorough analysis on the subject
TAT withdraws adverse remark against ICAI and its members in Vijay V. Meghani [2015] 61 taxmann.com 114 (Mumbai - Trib.) 04-09-2015
Para 9.6 of the order amended to substitute following remarks: However, if it is considered for a moment that the above said C.A. firm has really given such advice to the assessee herein and accordingly it has furnished the letter and affidavit, then it is a cause of concern to one and all. We have already noticed that the self study model coupled with "on-site articled clerk training" embedded in the Chartered Accountancy course aims to achieve high quality education and training .
CBDT Instructions no. 1916 dated 11-05-1994, requiring non seizure of jewellery to the extent of 500 gms for married lady, 250 gms for unmarried lady and 100 gms for male to be extended to assessment proceedings also and to be treated as explained income . The circular also explained by Hon'ble Ahmedabad I.T.A.T. in case of Kishorbhai V Sakaria, Rameshchandra R Patel 89 ITD 203 and Manila S Dave 117 Taxman 23- Ahemdabad Tribunal in RASIK GOPALDAS PATEL (2015) 45 CCH 0032 AhdTrib on 04-09-2015
Held by Calcutta High Court in Smt. Mina Deogun "We can imagine a situation where a person can be the owner of the land and another can be the owner of the structure. This is permissible in law because in joint ownership unity of title is not required. In the case before us the land admittedly belonged to the husband. He has raised the building with the joint funds belonging to himself and his wife. Therefore, one inference which can be drawn is that the land belonging to the husband has been thrown into the common stock of joint property between the husband and the wife. Both of them thus became the joint owners by operation of the doctrine of blending. They admittedly have borne the cost of construction in the ratio of 1/3rd and 2/3rd. Therefore, the income arising out of the property is in fact an income arising out of house property which has to be taxed under Section 22 rather than as an income arising out of other sources under Section 56. [2015] 60 taxmann.com 430 (Calcutta)
Due date extension from 31st Aug to 7th Sep is applicable to only those who were required to file return electronically. However as per Rule 12(3) Ind and HUF neither having income above 5 lacs nor having any refund claim and super senior citizens ( 80 yrs or above) can file return in paper form also. Hence there is no date extension for such categories of assesses
Sale of Shares held taxable under Short term capital gain and not profits and gains of business for following reasons: 1. No borrowings for purchase of Shares 2. Shares held for more than 30 days.( Shri Sugam Chand C. Shah Ahd Trib relied upon) 3. Had shares been held for business, stock would be been valued at cost or market price , whichever is less while in present case stock of Shares valued at cost only. 4. Shares reflected in Investment account. 5. Separate account maintained for F&O BHUPENDRA SHANTILAL SHAHITA No. 1496/Ahd/2011 (28-08-2015)(Ahd Trib)
Where land given for development, the capital gain shall arise in the year in which constructed flats handed over to land owner and not when Construction completed and accordingly exemption u/S 54/54F allowable in the year of taking flats.DR. S. VENKATESWARE PRASAD2015) 44 CCH 0563 HydTrib 28-08-2015
Monday, 31 August 2015
After SC Judgement in Suman Dhamija dtd 01-07-2015, CBDT has instructed the officers to file review petitions/ misc. applications in cases where appeals before 2011 were dismissed following low tax effect Instruction No. 3/2011dtd 09-02-2011 applied to pending cases filed before issue of these Instructions.Relevant Instructions Issued on 27-08-2015
In absence of fulfilment of fundamental fact that land was used for agriculture, merely mentioning of land as agricultural land in purchase deed or sale deed or even in revenue records cannot establish case of assessee that land sold by it was an agricultural land
Abhijit Subhash Gaikwad[2015] 60 taxmann.com 259 (Pune - Trib.)MAY 27, 2015
Punjab & Haryana High Court interpreting "service of notice/order" in Vat case: The order of appeal communicated by DETC A to the branch of the dealer, where as he had communicated head office address for communications, due to which there was delay of 907 days in filing appeal to the VAT Tribunal. The Vat Tribunal upheld the service under section 27 of General Clauses Act. Punjab and Haryana High Court however held quoting ” The Commissioner of Income Tax, Punjab, Haryana, Jammu and Kashmir, Himachal Pradesh and Chandigarh, Patiala V/s Lalita Kapur’ (P&H)(DB), 1970 CurLJ 523, that Division Bench of this Court has already held that presumption under Section 27 of the General Clauses Act, 1897 stands rebutted in case the service is effected on an assessee under Section 63 (1) of the Income Tax Act, 1922 through its agent never appointed by it, as it shall not be a valid service”. Hence service is invalid and delay condoned- M/s. B.K. Steels VAT AP 214/2014 dated 10-08-2015 Comments: Section 27 of General Clauses Act is applicable under Income tax law also, by virtue of Section 282 of Income tax Act. The above Judgement substantiated that presumption u/S 27 is not non rebuttable.
Friday, 28 August 2015
No service tax on food served by home delivery/pick up
Clarified by Service Tax Department of Chandigarh vide
letter dated 13-08-2015 that no service tax shall be charged for home delivery/pick
up of food because dominant purpose is not enjoyment of services like ambience,
air conditioning or personalized hospitality. Service tax can be charged only
if element of service is involved. Earlier restaurants such as McDonald’s, Domino’s, Pizza Hut etc.
were providing home delivery/pick up facility and were also charging service
tax. This clarifications shall bring much sought for relief to consumers
Monday, 24 August 2015
A contract was entered by assessee- joint venture company to execute project work for its client - Assessee did not execute contract work and said work was done by one of its constituents, namely 'SMS Ltd.' - Receipts for project work were reflected in books of account of 'SMS Ltd.' and in return, 'SMS Ltd.' had disclosed said income and assessment was completed - Whether since there was no finding of receipt of any income by assessee on account of said contract, same would not be treated as income in hands of assessee
SMSL-UANRCL (JV) MARCH 2, 2015 60 Taxmann.com 206
assessee sold immovable property resulting in capital loss - On basis of valuation made by sub-registrar, Assessing Officer issued notice to assessee for adoption of higher sale value of property - In response to said notice, assessee submitted revised computation of income showing increased selling price to assessee - Assessing Officer accepted said valuation and completed assessment - Subsequently, he initiated re-assessment proceeding on ground that certain long-term capital gain arising out from sale of property escaped assessment - Whether mere fact that in response to notice issued by Assessing Officer, assessee had filed revised computation of income, not revised return of income, therefore it could not be ground to reopen assessment - Held, yes - Whether, moreover, assessee had disclosed all relevant facts at time of assessment, initiation of re-assessment proceedings after expiry of 4 years, from relevant year, merely on basis of change of opinion was not sustainable
Chandrakant Keshavram Singapuri [2015] 60 taxmann.com 136 (Gujarat) MARCH 11, 2015
Where principal objects of assessee were to encourage study of theory of banking and for that purpose to institute a scheme of examinations and to give certificates, scholarships and prizes, activities of assessee would squarely be covered by definition of charitable purpose and it was eligible for exemption under section 11
Indian Institute of Banking & Finance[2015] 60 taxmann.com 193 (Mumbai - Trib.) FEBRUARY 11, 2015
Section 115BBC taxing anonymous donations @ 30% is not applicable to trust being a temple or shrine; provisions of this section are meant to check inflow of unaccounted/black money into system with a modus operandi to make out as a part of accounts of institutions like university, medical institutions where problem relating to receipt of capitation fees, etc. is generally highlighted. Such type of offerings are made/put into the donation box by numerous visitors and its generally not possible for any such type of institutions to make and keep record of each of the donor with his name address etc. Even sometimes the donors out of their esteem, respect and regard and selflessness they do not want that their name be registered as a donor before the deity for whom them make the prayer in the belief that the deity is the ultimate giver of all the worth and virtues of their life. Gurudev Siddha Peeth JULY 22, 2015 ITAT MUMBAIIT APPEAL NOS. 3466 AND 3467 (MUM.) OF 2012
Income/loss from letting out of multiplex/shopping mall and cinema theatre along with amenities was to be assessed under head ‘business income’ of the assessee and not ‘Income from house property’ as main intention was found to be exploitation of property by way of commercial activities. As held by Apex Court in Chennai Properties & Investment Ltd that where the letting of the properties was in fact the business of the assessee, the income arising therefrom was to be treated under the head “Income from Business” and that it cannot be treated as income from House Property. Thus, assessee was also entitled to the claim of deductions in respect of expenditure incurred and depreciation on assets etc. in relation to such income SHREEJI EXHIBITORS vs.ASSISTANT COMMISSIONER OF INCOME TAX BOMBAY TRIBUNAL Aug 14, 2015 (2015) 44 CCH 0492 MumTrib
Deduction made from contractor's bill on account of amount being receivable upon there being no defect during stipulated period shall not be included in his income although he is following mercantile system . Held by Andhra Pradesh High Court in Shankar Constructions . ITA 135/2004. High Court discussed the principles propounded by Supreme Court inCIT v. Shoorji Vallabhdas & Co. [1962] 46 ITR 144 (SC) , CIT v. A. Gajapathy Naidu [1964] 53 ITR 114 (SC) .
CBDT Instruction No. 5 of 2014 revising monetary limit to Rs. 4 lakhs for filing appeal before Tribunal shall apply to pending appeals also. Since monetary limit of appeal filed by revenue was less than Rs. 4 lakhs, same was to be dismissed-Gurudayal Sontosh Kumar[2015] 60 taxmann.com 24 (Kolkata - Trib.)FEBRUARY 4, 2015
Wednesday, 19 August 2015
Cuttuck Tribunal in N.K. Media Ventures 59 taxmann.com 365 following Mumbai Tribunal in Porwal Creative 50 SOT 148 has held that since no TDS return can be filed till payment of tax, no penalty u/S 272A(K) can be levied from due date of filing TDS return till date of tax payment. Although Section 234E had reigned over S. 272A(K) wef 01-07-2012, it contains similar provisions, hence Judgement might become applicable to 234E also-
For educational Institutions being granted approval u/s 10(23C)(vi) (CIRCULAR NO.14/2015 dated 17-08-2015) following postulates put accross:
1. Guidelines of Supreme Court in American Hotel and lodging 301 ITR 86 to be followed.
2. No denial to be made where compliance depends upon events that have not taken place till date of application.
3. Institution granted registration both under S. 12AA and 10(23C)(vi), no automatic withdrawal of approval where 12AA registration cancelled unless conditions under 10(23C) are violated.
4. No withdrawal of approval for accumulation of profit be cause the third Proviso to the said clause clearly provides that accumulation of income is permissible subject to the manner prescribed therein provided such accumulation is to be applied "wholly and exclusively to the objects for which it is established.
5.Collection of small and reasonable amounts under different heads of fee, which are essentially in the nature of fee connected with imparting education and do not violate any Central or State regulation does not, in general, represent a profit making activity E.g. application fee, examination fee, fee for issuing transfer certificate, subscription fee for library.
6. Extra ordinary powers of managing trustees to appoint other trustee and their heirs also shall not result in denial of approval
2. No denial to be made where compliance depends upon events that have not taken place till date of application.
3. Institution granted registration both under S. 12AA and 10(23C)(vi), no automatic withdrawal of approval where 12AA registration cancelled unless conditions under 10(23C) are violated.
4. No withdrawal of approval for accumulation of profit be cause the third Proviso to the said clause clearly provides that accumulation of income is permissible subject to the manner prescribed therein provided such accumulation is to be applied "wholly and exclusively to the objects for which it is established.
5.Collection of small and reasonable amounts under different heads of fee, which are essentially in the nature of fee connected with imparting education and do not violate any Central or State regulation does not, in general, represent a profit making activity E.g. application fee, examination fee, fee for issuing transfer certificate, subscription fee for library.
6. Extra ordinary powers of managing trustees to appoint other trustee and their heirs also shall not result in denial of approval
Penalty of Rs. 10,000/- u/s 271(1)(b) for not complying with sec. 143(2)couldn't be imposed more than once for same default . The provision of Section 271(1)(b) is of deterrent nature and not for earning revenue. Hence penalty of Rs. 50000 confirmed by CIT (A) reduced to Rs. 10000 by Delhi Tribunal in Smt. Rekha Rani IT APPEAL NO. 6131 (DELHI) OF 2013 DATED 06-05-2015
Where assessee, engaged in business of land developers, borrowed certain amount from financial institutions for its business activity, interest paid on said loan had to be allowed as deduction under section 36(1)(iii)
Modi Builders[2015] 60 taxmann.com 54 (Pune - Trib.) JUNE 26, 2015
Assessee-firm advanced money to two ladies without interest out of interest bearing funds allegedly to acquire properties for firm in course of business - However, no evidence was produced by assessee to justify its stand - Assessee claimed interest paid on borrowings - Whether since amount advanced out of interest bearing funds was not for business purpose, interest attributable to money advanced to said two ladies could not be allowed as deduction - Held, yes
Akarshan Builders [2015] 60 taxmann.com 138 (Karnataka) DECEMBER 2, 2014
No concealment penalty if sum treated as capital receipt was disclosed in notes to accounts and return
The respondent-assessee had originally paid an amount of Rs.54 Lakhs as a consideration for the development agreement in 1995. In the previous year relevant to assessment year, the respondent-assessee received from the vendor an amount of Rs. 1.65 Crores which included an amount of Rs. 54 Lakhs which was originally paid in 1995 by the assessee to the vendor.
The department imposed tax on the assessee and the assessee accepted the position. However held by Bombay High Court in S.M. Construction [2015] 60 taxmann.com 135 (Bombay) following Supreme Court inCIT v. Reliance Petroproducts (P.) Ltd. [2010] 322 ITR 158/189 Taxman 322 and distinguishing CIT v. Zoom Communication (P.) Ltd. [2010] 327 ITR 510/191 Taxman 179 (Delhi) (para 9)disclosure of Rs. 1.11 Crores which was made by the petitioners as a part of its notes to accounts as well as letter dated 29 October 2005 alongwith its claim of not being taxable was filed along with the Return of Income. Thus there has been a complete disclosure of all facts as held by CIT(A) and the Tribunal
The department imposed tax on the assessee and the assessee accepted the position. However held by Bombay High Court in S.M. Construction [2015] 60 taxmann.com 135 (Bombay) following Supreme Court inCIT v. Reliance Petroproducts (P.) Ltd. [2010] 322 ITR 158/189 Taxman 322 and distinguishing CIT v. Zoom Communication (P.) Ltd. [2010] 327 ITR 510/191 Taxman 179 (Delhi) (para 9)disclosure of Rs. 1.11 Crores which was made by the petitioners as a part of its notes to accounts as well as letter dated 29 October 2005 alongwith its claim of not being taxable was filed along with the Return of Income. Thus there has been a complete disclosure of all facts as held by CIT(A) and the Tribunal
Friday, 14 August 2015
In the absence of any assessment , taking of cheques by ETO of mobile wing is not justified. Rs. 10,000 penalty imposed
Sumit Agencies (8-07-2015) 25 STM 148
[P&H HC]
Provisional Assessment can not be made by member of raiding team
Sumit Agencies (8-07-2015) 25 STM 148
[P&H HC]
Non Speaking order passed by authority can not be sustained. Order set aside and designated order asked to pass reasoned order with in three months.
Arora Steel
[27-04-2015] PVAT TRI 25 STM 141
Input Tax Credit can not be denied to the purchasing dealer on the ground that the registration of the selling dealer was cancelled after the sales were made or that they did not deposit the full tax in the treasury unless there is malafide intention, connivance or wrongful association of the purchaser with the seller or any dealer earlier there to
Gheru Mal
Bal Chand [2011] 17 STM 465; Delhi High Court
Shanti Kiran India Ovt Ltd. [2013] 20 STM 168 (Del HC)
. Rule 86 of Punjab Vat Rules prescribing modes of serving notices to the dealer does not contemplate notice by publishing on website. Such a publishing for assessment as well as reassessment is bad in law. Section 149 of Municipal Corporation Act which contemplates service of notice by beating of drum and play cards posted at conspicuous place can not be applied
Olam Agro
India Ltd. 25 STM 114 [20-08-2013]
Sony India
Pvt Ltd. 25 STM 144 [27-04-2015] following Olam Agro India Ltd. [2015]
Power of Reassessment u/s 29(4) Proviso can not be invoked without affording opportunity of being hearing to the dealer
A.B. Sugars
Ltd. [2010] 15 STM 90(P&H HC)
Thursday, 13 August 2015
ITC Carried forward for earlier assessment year can not be rejected on the ground that it has not been verified.
H.M. Steels
Ltd. 25 STM 186 (PVAT Tri) 30-03-2015
Where assessee, a civil contractor, made payments to transporters and sub-contractors in course of its business, in view of fact that assessee gave complete addresses and PANs of payees and, moreover, said payments had been made after deducting tax at source, impugned order rejecting assessee's books of account was to be set aside
V.V. Constructions[2015] 59 taxmann.com 368 (Pune - Trib.) JUNE 12, 2015
For relevant assessment year, assessee-firm declared gross profit rate (GPR) of 25.38 per cent as against 29.5 per cent declared in immediate preceding year - Assessing Officer was not satisfied with assessee’s explanation regarding decline in GPR and, therefore, he rejected its books of account and applied GPR at 27 per cent which resulted in certain addition - On appeal, Commissioner (Appeals) deleted addition holding that Assessing Officer made addition without pointing out any specific defect in books of account - Tribunal upheld finding of Commissioner (Appeals) - Whether there was any perversity in order of Tribunal - Held, no
Om Overseas [2008] 173 TAXMAN 185 (PUNJ. & HAR.) HIGH COURT OF PUNJAB AND HARYANA MARCH 4, 2008
On assessee’s inability to supply addresses of purchasers who purchased goods on cash, ITO rejected assessee’s books of account showing result in respect of cash sale transactions, and made addition – AAC deleted additions but Tribunal restored ITO’s orders – Whether there was no necessity whatsoever for assessee to maintain addresses of cash customers – Held, yes – Whether, therefore, rejection of book results of assessee was unjustified – Held, yes – Whether, consequently, additions made to assessee’s income were liable to be deleted – Held, yes
R.B. Jessaram Fatehchand (Sugar Dept.)[1970] 75 ITR 33 (BOM. HIGH COURT OF BOMBAY JULY 30, 1969
FDR Interest is not Business Income
The Hon'ble Rajasthan High Court had held in the of Murli Investment Co v. CIT 167 ITR 368 (Raj.) that merely investing surplus funds instead of keeping them idle and obtaining interest thereon would not constitute business and therefore, the interest by the assessee would not be assessable as business income but assessable as income under other sources. The Hon'ble Kerala High Court in the case of CIT v. Venad Conductors (P) Ltd. 326 ITR 513 (Ker.) had held that income from short term deposit cannot be treated as income from business but it is income from other sources. Likewise, in the case of T.O. Abraham & Company v. Dy. CIT 325 ITR 201 (Ker.) It was held that interest income from bank deposits is assessable under the head "income from other sources" where the assessee is not engaged in money lending business. The Himachal Pradesh High Court in the case of Shanta Lal Chopra v. CIT 2008 214 CTR 420 (HP) had held that the interest on FOR pledged with bank for obtaining loan was assessable as income from other sources and not business income. Similar view was taken by the Hon'ble M.P High Court and Hon'ble Madras High Court respectively in the cases of Ferro Concrete Construction (lndia)(P) Ltd. v. CIT 290 ITR 713 (MP) and CIT v. Monark Tools (P) Ltd. 260 ITR 258 (Mad.). The Hon'ble Delhi High Court in their later on decisions had also taken the view that, interest income is assessable as income from other sources. In the case of CIT v. Shri Ram Honda Power Equip. (Delhi) 289 ITR 475 (Delhi), the Hon'ble Delhi High Court had held that where surplus funds are parked with the bank and interest is earned there on it can only be categorized as income from other sources. The other category is where the exporter is required to mandatorily keep monies in fixed deposits in order to avail of credit facility for the export business. Interest earned on fixed deposits for the purpose of availing of credit facility from the bank, does not have an immediate nexus with the export business and therefore has to necessarily be treated as income from other sources and not business income.
(Para 2.3 and Para 2.4 in Almac Corporation [60 taxmann.com 34][Ahd Trib]
(Para 2.3 and Para 2.4 in Almac Corporation [60 taxmann.com 34][Ahd Trib]
Where Assessing Officer disallowed a part of remuneration payable by assessee-firm to its partners under section 40(b)(v) on ground that interest on FDRs was to be excluded for purpose of calculation of remuneration payable to partners, since no such adjustment had been made by him while computing income from business, impugned disallowance was to be deleted
Almac Corporation [2015] 60 taxmann.com 34 (Ahmedabad - Trib.) APRIL 10, 2015
Saturday, 8 August 2015
Where Assessing Officer rejected books of account and estimated net profit on gross receipts, Commissioner could not invoke revisional power
Gopal Narayan Singh (Patna Trib) 4-07*-2014 53 taxmann.com 51
Section 145, read with section 263, of the Income-tax Act, 1961 - Method of accounting - Rejection of accounts (Revision) - Assessment year 2007-08 - Assessing officer estimated net profit of assessee at 5.58 per cent of gross turnover from civil contract work - Commissioner invoked section 263 alleging that there was inability to produce evidences in support of assessee's claim of expenses and profit - It was found that in opinion of Assessing Officer, books of account were not reliable and, accordingly, he rejected books of account and estimated said profit of his own - Whether Commissioner could not invoke section 263 by mentioning that no proper enquiry had been made by Assessing Officer when nothing had been brought on record by Commissioner - Held, yes - Whether, therefore, Commissioner was not justified in cancelling assessment order - Held, yes [Para 5] [In favour of assessee]
Section 145, read with section 263, of the Income-tax Act, 1961 - Method of accounting - Rejection of accounts (Revision) - Assessment year 2007-08 - Assessing officer estimated net profit of assessee at 5.58 per cent of gross turnover from civil contract work - Commissioner invoked section 263 alleging that there was inability to produce evidences in support of assessee's claim of expenses and profit - It was found that in opinion of Assessing Officer, books of account were not reliable and, accordingly, he rejected books of account and estimated said profit of his own - Whether Commissioner could not invoke section 263 by mentioning that no proper enquiry had been made by Assessing Officer when nothing had been brought on record by Commissioner - Held, yes - Whether, therefore, Commissioner was not justified in cancelling assessment order - Held, yes [Para 5] [In favour of assessee]
Sunday, 2 August 2015
AO couldn't make estimated additions without showing comparable case to justify higher rate of net profit
Section 145 of the Income-tax Act, 1961 - Method of accounting - Estimation of income (GP Rate) - Assessment year 2009-10 - Assessee - a partnership firm, was engaged in business of civil contractor and had furnished his income-tax return along with audit report and other information - Assessee declared a net profit of 5.38 per cent, subjected to interest and remuneration to partners - A perusal of order revealed that net profit rate in immediate preceding year was 5.02 per cent - Assessing Officer invoked provisions of section 145 and disallowed expenses amounted to Rs. 1.17 crores and determined net profit at 13.7 per cent - Commissioner (Appeals) sustained an ad hoc addition of Rs 10 lakhs - Tribunal reduced addition to Rs 5 lakhs - It was observed by Tribunal that though contract receipts had sharply increased from Rs 10.60 crores to Rs. 12.32 crores, net profit had increased from 5.02 to 5.38 per cent with addition of Rs 5 lakhs - Whether as Assessing Officer had failed to bring on record any comparable case so as to justify any estimation/addition, order of Tribunal was to be upheld - Held, yes [Paras 10 and 11] [In favour of assessee]
[2015] 59 taxmann.com 293 (Rajasthan)/[2015] 371 ITR 325 (Rajasthan)
[2015] 59 taxmann.com 293 (Rajasthan)/[2015] 371 ITR 325 (Rajasthan)
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