2000 (2) TMI 62

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..... The facts giving rise to this appeal, briefly, are as follows : The respondent-company is a pharmaceutical company. It took over the assets of the Indian branch of May and Baker Limited, U. K. on January 1, 1975. In the original returns for the assessment years 1976-77 and 1977-78, the respondent did not claim depreciation on the assets of the Indian branch. However, for the assessment yea....

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....oints also debatable was the applicability of rule 10. However, if one goes into the terms of the settlement, it is clear that finally in order to buy peace an ad hoc figure of underassessment was arrived at and it was accepted by the assessee. On the basis of this ad hoc figure of underassessment the Department now contends that the assessee was guilty of furnishing inaccurate particulars and tha....