2012 (2) TMI 582

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....CIT(A)'s order dated 8-9-2010 relating to A.Y. 2006-07. Following effective ground are under: "I. That the learned Commissioner of Income-tax (Appeals) has erred in confirming the disallowance of ₹ 50,000/- paid towards filing fee to ROC. II. That the learned Commissioner of Income-tax (Appeals) has erred in confirming the disallowance of ₹ 13,49,170/- incurred on moulds & dies use....

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....el for the assessee has applied for filing of additional evidence, which could not be furnished before the AO. 6. Brief facts are that the assessee is in the manufacture of plastic containers involving the purchase of moulds and dies. The quality of products depends upon the quality of moulds used by the assessee. In the course of business, purchases include two types of moulds - one of good qual....

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....ssessee has employed the practice of capitalizing of the moulds as a block of asset, claiming depreciation thereon. The orders of lower authorities are relied on. 8. We have heard rival contentions and perused the relevant material available on record. In similar facts additional evidence was admitted and issue was set aside by the ITAT and restored back to the file of AO for A.Y. 2005-06. We hav....