2011 (3) TMI 1658

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....eal is filed by the assessee having been aggrieved by the order dt.11.2.2010 of the Commissioner of Income-tax (Appeals) for Assessment Year 2005-06 in the case of the assessee. 2. Grounds No.1 and 4 are general in nature and need no specific adjudication and they are dismissed as such. 3. Ground No.3 relates to addition of ₹ 7,152 u/s.36(1)(va) pertaining to contribution to EPF. At the ti....

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...., Balance Sheet, Schedules forming part of the Balance Sheet, Auditors Report as per the provisions of the Income-tax Act,1961. During the assessment proceedings, the assessee along with its Accountant appeared from time to time with relevant books of account, documents, ledger accounts supported with vouchers for expenses etc., on various dates. While completing the assessment, the Assessing Offi....

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....ia) of the Income-tax Act,1961. In appeal, the learned CIT(A) confirmed the same. Challenging this disallowance, the learned AR of the assessee contended before the Tribunal that the provisions contained in Section 40(a)(ia) of the Act states the amount "payable" but not "paid already". In support of his contention he relied on the following authorities apart from the provisions contained in Secti....

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....he rule of liberal construction of taxing provisions. Therefore, the learned AR of the assessee sought deletion of the disallowance made by the lower authorities. Contrary to this, the learned DR vehemently argued in support of the impugned orders of the authorities below. 7. On perusal of the above stated orders of the Tribunal as well as the decisions of Hon'ble Supreme Court and the CBDT Circu....