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2005 (12) TMI 262

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....ot reproduced here as they involved minor issues] 6. With respect to the second issue agitated by the Revenue, the learned counsel submitted that no monitary limit has been assigned to claim pooja expenses which are invariably incurred in the business premises for the purpose of business. The details furnished by the assessee clearly indicate that the monthly Dakshina being salary given to the ....

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....rowed funds on which interest has been charged in the profit and loss account without establishing nexus was considered fit for deletion by the learned CIT (Appeals). 8. We have heard the rival contentions and perused the material available on record. The first ground agitated by the Revenue stands covered against the Revenue insofar as the learned DR has rightly conceded the applicability of v....

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.... was maintaining a temple with Daxina or salary could not be assigned to any business conducted by the assessee. The learned CIT (Appeals) erred in considering that all the expenses incurred under the guise of pooja could be related to business activity of the assessee was not on the basis of facts otherwise noted by the Assessing Officer. Before us also the learned counsel has not been able to sp....

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....ss aside. The nexus for establishing the construction having been met out of the borrowed funds was clearly established by the Assessing Officer insofar as it was under construction which was shown by the assessee as capital work in progress. The borrowings, therefore, were utilized in the construction which has not been disputed by the assessee. Therefore, we do not find merit in the deletion of ....