2016 (1) TMI 224

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....850/Chandi/94 for the assessment year 1987-88, claiming following substantial questions of law:- "i) Whether on the facts and circumstances of the case, the ITAT was right in holding that the expenditure incurred for employees is business expenditure and is an allowable deduction and not covered under the head entertainment expenses? ii) Whether on the facts and circumstances of the case, the ITAT was right in holding that the report of the auditor can be furnished before completion of assessment and accordingly deduction under section 80HHC is allowable in this case particularly when the ratio of the decision of the jurisdictional High Court in the case of CIT vs. Jaideep Industries reported in (1989) 180 ITR 81 supports ....

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....ioner of Income Tax (Appeals) [CIT(A)]. Vide order dated 13.5.1994, Annexure A.2, the CIT(A) partly allowed the appeal of the assessee. On the issue of disallowance of Rs. 3,51,199/- under section 37(2A) of the Act, the relief was declined but the CIT(A) allowed the deduction under Section 80HHC of the Act by placing reliance on judgment of the Gujarat High Court in CIT vs. Gujarat Oil and allied Industries, (1993) 201 ITR 325. Still not satisfied, the assessee and the revenue both filed appeals before the Tribunal. Vide order dated 27.7.2000, Annexure A.3, the Tribunal partly allowed both the appeals. It allowed deduction of Rs. 65,000/- as expenditure incurred for employees relying on its own order in the case of the assessee for the earl....