2018 (5) TMI 635

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....ar JUDGEMENT ( Judgement of the Court was delivered by T.S.Sivagnanam, J. ) These Appeals by the assessees are directed against the common order passed by the Income Tax Appellate Tribunal, 'A' Bench, Chennai, (for short, ITAT), dated 25.08.2006, in I.T. (SS) A.Nos.133 and 134 /Mds/2002, for the Block Assessment Period from 01.04.1988 to 20.09.1998. 2. T.C. (A) No.857 of 2008, ....

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....d income, on estimate of proportionate income on the basis of the income disclosed for the assessment year 1999-2000? 4. The issue involved in both the Tax Cases lie in a very narrow compass. 5. The apprehension of the petitioners/assessees is that, they would be taxed twice for the same Block Assessment Period, i.e., 01.04.1988 to 20.09.1998. This apprehension is because, the assessment for....

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.... that, the contention raised by the assessee is incorrect, and the law laid down by the Hon'ble Supreme Court, in Assistant Commissioner of Income Tax, Chennai Vs. A.R. Enterprises, reported in [(2013) 29 Taxmann. Come 50 (SC)] fully supports the stand taken by the Revenue. 8. We have heard Mr.Philip George, the learned counsel appearing for the appellant and Mr.T.R.Senthil Kumar, the learn....

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....08 is concerned, the ITAT took into consideration, the claim made by the assessee; and whether the payment effected by them for acquiring the membership in a Social Club should be allowed, and after considering the factual matrix and re-appreciating, what was placed before the Commissioner of Income Tax Appeals, in our opinion, rightly held that the personal expenses cannot be allowed as business ....