Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1982)1ITD476(Chd.)
1. This appeal by the assessee is directed against the order of the Commissioner (Appeals) dated 20-7-1980 relating to the assessment year 1979-80. The only issue involved in this appeal is whether, on the facts and in the circumstances of the case, the sustentation of the addition of Rs. 58,720 representing the amount earmarked for expenditure to be incurred by the assessee to discharge its liability by way of post warranty services of the Eicher Tractors dealt in by it, is justified 2. We have heard the parties. The facts which we have to take into consideration for determination of this issue are as under: The assessee Singhal & Co., is a registered firm consisting of two partners, namely, Dharam Chand and Suraj Prakash, having shares in the profits and losses of the firm in the ratio of 70 : 30. The assessee deals in Richer Tractors. After a tractor is sold, there is a period provided for free service by the dealer the expenses of which are reimbursed by the manufacturers. How...
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1984)8ITD338(Chd.)
1. This appeal by the assessee, against the imposition of penalty under Section 271(1)(c) read with Section 274 of the Income-tax Act, 1961 ('the Act') by the IAC for the assessment year 1965-66, raises a very interesting question of law. But before we record and proceed to consider the question of law raised in this appeal, we would, in brief, record the facts leading to it.2. The assessee, Seth Panchhi Ram & Co., Manali is assessed in the status of a HUF and for the assessment year 1965-66, its original assessment was completed under Section 143(3) of the Act on 17-3-1970 at a total income of Rs. 1,02,300 on the basis of a return dated 7-8-1965 declaring income of Rs. 11,09,350 which was however, revised to Rs. 89,318 on 10-8-1967. On the basis of that assessment, a penalty under Section 271(1)(c) was levied by the IAC on 24-3-1972. The said original assessment order came up in appeal to the Tribunal and the Tribunal by its order in IT Appeal No. 1069 of 1970-71, dated 5-11-1973...
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