2013 (11) TMI 136

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....(Appeals)-XXX, Kolkata in Appeal No. 135/CIT(A)-XXX/Circle-46/2009-10 dated February 24, 2012. The assessment was framed by the Assistant Commissioner of Income-tax, Circle-46, Kolkata, under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the "Act"), for the assessment year 2007-08 vide his separate order dated November 26, 2009. The only issue in this appeal of the assesse....

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....urse of assessment proceedings found that the assessee has debited a sum of Rs. 2,94,000 on account of managers' salary. The salary paid to Dipankar Panja was a sum of Rs. 1.74 lakhs and to Tanusree Panja was a sum of Rs. 1.20 lakhs, both being son and daughter-in-law of the assessee. The Assessing Officer disallowed one-third of the salary credited to Dipankar Panja and Tanusree Panja, that comes....

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....-tax (Appeals) has not examined the plea raised or services rendered by these persons as clarified before him. Even the Assessing Officer has not brought on record any reason why he has estimated disallowance. There is no whisper that these two employees, i.e., the managers, even though they may be son and daughter-in-law, have not carried out any business or rendered any services. The assessee be....