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2018 (4) TMI 90

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....p; RESPONDENT: R. BY ADV. SRI.JOSEPH MARKOSE (SR.) R. BY ADV. SRI. V. ABRAHAM MARKOS R. BY ADV. SRI.BINU MATHEW R. BY ADV. SRI.TOM THOMAS (KAKKUZHIYIL) R. BY ADV. SRI.ABRAHAM JOSEPH MARKOS R. BY ADV. SRI.ABRAHAM VARGHESE THARAKAN   JUDGMENT K. Vinod Chandran, J. Both the Income Tax Appeals are with respect to the very same issue the slight difference on facts in so far as the assessee in ....

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....e facts found by the assessing officer based on the letter of the assessee and is not the finding and conclusion of the ITAT to the contrary perverse? 2. a) Whether on the facts and in the circumstances of the case and the Assessment order being confined to the submissions and the letter noted in paragraph 3 of the order, the Commissioner of Income Tax [Appeals] and the Tribunal are right in law ....

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....assessee carried out tour operations by its own vehicles and when the assessee required another vehicle, then it was hired and again the driver was paid by the assessee and so was the diesel expenditure met by the assessee. 4. The Appellate Authority and the Tribunal in the same voice reversed the order of the Assessing Officer. The Tribunal also noticed Section 194-I of the Income Tax Act, 1961 ....

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....l persons, who had subscribed to the tour programme. The dis-allowance was with respect to the expenses claimed, in so far as the hiring of vehicles carried out by the respective assessees. The expenses claimed by the assessee were disallowed as a consequence of the non-deduction of TDS and an addition was made, to the extent provided for in Section 40(a)(ia). 6. The hiring of vehicles, on the co....