TaxTMI 
TaxTMI 
2019 (4) TMI 681
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....MBER) 1. Aforesaid appeal by revenue for Assessment Year [in short referred to as 'AY'] 2014-15 contest the order of Ld. Commissioner of Income- Tax (Appeals)-5, Mumbai, [in short referred to as 'CIT(A)'], Appeal No.IT- 406/16-17 dated 03/10/2017 on following grounds of appeal: - "1."Whether on the facts and in the circumstances of the case and in law, the ld. CIT(A) was right in deleting the a....
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.... engaged in the business of export / import of chemicals etc. and trading in computer parts was assessed for impugned AY u/s 143(3) on 28/12/2016 by Ld. Assistant Commissioner of Income Tax- Circle 2(2)(2), Mumbai [AO] wherein the income of the assessee was determined at Rs. 312.99 Lacs after certain additions as against returned income of Rs. 297 Lacs filed by the assessee on 30/09/2014. As evide....
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.... in the nature of Linux Version-1, VMS Ent./Std. Addition, Re purposing software etc. which was stated to be purchased at rates ranging from Rs. 1000/- to Rs. 1600/-. However, finding the rates to be excessive and unreasonable and observing that Linux was free and open-source software, Ld. AO disallowed the same. 3. The assessee agitated the same with detailed submissions before Ld. first appella....
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....nd perused relevant material on record including documents placed in the paperbook. Upon perusal, the undisputed position that emerges is the fact that the assessee has purchased the stated software under 6 bills for resale. The part of these software has been sold by the assessee during impugned AY and the balance software have been reflected as Closing Stock under the head electronics which is....