1983 (2) TMI 138

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.... drugs and chemicals from 1st April 1962. M/s T.R.C. Meenakshisundaram Brothers is another firm dealing in textiles form 1972. Both the firms have the same constitution as well as the same profit sharing ratio. It appears, the ITO had till now given separate registration to these two firms as genuine firms. The ITO mainly because of (1976) 104 ITR 28 (AP) (Addl. CIT v. M. Venkatanarasimha Rao & Co....

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....rtmental ground where it is stated that there is evidence in the record of interlacing and interdependence between the two firms since whenever one of the firms required funds it is passed on by the other, an expression significantly omitted in the assessment order. It is clear that the assessment were made only on the basis of the legal proposition expounded in (1976) 104 ITR 28 (AP) that it is i....

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....t statement clearly shows that the ITO had not proceeded on such facts of interlocking and interlacing. In (1980) 14 CTR (AP) 334 (FB) : (1980) 121 ITR 97 (AP) (FB), it is stated that if there is interlocking and interlacing of funds between the two firms, then it is permissible to make one assessment. This allegation in department ground that this interlocking and interlacing is, therefore, only ....