TaxTMI 
TaxTMI 
2022 (4) TMI 1499
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....erence to special audit under section 142(2A) is illegal and bad in law and the report submitted by the special auditor is illegal, bad in law and without jurisdiction. 2. That the special auditor has erred on facts and in law in scrutinizing and auditing those issues which are not part of the terms of reference and has exceeded his jurisdiction in making observations about those issues in the audit report submitted. 3. That in view of the facts and circumstances of the case and in law the A.O. has erred in completing the assessment U/s 143(3)/l44C at Rs. 10,04,09,220/- as against returned income of Rs. 2,45,71,610/- (after disallowing deduction under chapter VIA). The additions made are unjust, unlawful, bad in law, without jurisdiction and are also highly excessive. On Transfer Pricing 4. That the reference made to the TPO is illegal and bad in law and the order passed u/s 92CA(3) is illegal, bad in law and without jurisdiction. 4.1 That in view' of the facts and circumstances of the case and in law the AO /TPO has erred on facts and in law in making addition of R.s. 64,48,052/- (Rs.9,23.713/- + Rs. 32,86,303/- + 22,38.036/-) on ac....
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....ature of personal expense. 7.1 That in view of the facts and circumstances of the case and in law the erred in law and on facts in taking wrong, figure of. addition under the head personal expenses. Disallowance of Deduction of Bad Debts 8 That in view of the facts and circumstances of the case and in law the A.O./D.R.P has erred in not allowing the deduction of 17,82,951/- claimed as bad debts by the appellant while computing the income under the Income Tax Act, 1961. Disallowance U/s 40a(ia) on Account of Non/Short Deduction of TDS 9 That in view of the facts and circumstances of the case and in law the A.O./DRP has erred in holding that the assessee has not deducted TDS or there is a shortfall in deduction of TDS while making payment to various concerns and further held that the same is to be disallowed under section 40a(ia) to the tune of Rs 2,66,21,033/- (Rs.7,26,890/- + Rs. 2,58,94,143/-) and the addition of Rs. 3,15,46,346/- has been made. 9.1 That the DRP has in view of the facts and circumstances of the case has erred in law and on facts in holding that identical issues has come up for their consideration in appellant's....
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....ice charged on sale of rice to AE is higher/within range +/- 5% of the price charged from un-related third parties. Therefore, transaction of export of rice to AE was considered to be at arm's length price by the assessee. 11. In the alternative, the assessee has also benchmarked the said transaction applying TNMM. For application of TNMM profit over sales earned by the assessee from sales made to AE is computed with profit over sales earned from sales made to unrelated third parties in export and domestic market and the same is available at page 59 of the paper book which can be summarized as under: AE/ Non-AE Brands OP/ Sales AE - KUSHA (USA) ROYAL BRAND 16.88% OTHER BRAND 13.51% AE - NICE ALL BRAND 9.24% Average 16.08% NON-AE BASMATI (EXPORT) 10.76% NON-BASMATI (EXPORT) 4.44% DOMESTIC RICE (ALL BRANDS) 2.23% AVERAGE 6.26% 12. On the basis of the above analysis, under TNMM, the said transaction was considered to be at arm's length price by the assessee. 13. We find that during the course of TP assessment proceedings, the TPO required the assessee to provide comparison of price of goods ....
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....emed to be ALP." 18. In the explanation, it has been mentioned that provisions of second proviso shall also be applicable to all assessments or reassessment proceedings pending before the Assessing Officer as on the first day of October 2009. The order of the TPO is dated 30.10.2011, which means that the amended second proviso was very much applicable on the facts of the case. 19. In our understanding of the amended proviso, the arm's length range of 5% is required to be computed qua arithmetical mean of the ALP determined by the TPO was changed to arm's length range of 5% required to be computed qua transaction price. 20. Similar view was taken by the coordinate bench in the case of DDIT Vs. Development Bank of Singapore 155 TTJ 265 wherein the coordinate bench has held that benefit of range of +/- 5% is available not only to a situation where more than one price is determined as ALP by the most appropriate method but also where only one price is determined as ALP. 21. In light of the amended provision, let us now consider the transaction of export of rice undertaken by the assessee with its AE and the same is as under: Party Date FOB Val UE (IN RS.) Av.....
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....d the arm's length rate of interest at 17.26% on the basis of information sought from Crisil Ltd under section 133(6) of the Act which provided yield from BBB rated Bond at 14.39%. 28. Since the credit rating of the AE was not available, the TPO assumed credit rating of AE to be D and formed a belief that the arm's length rate of interest charged by the assessee ought to be 20% over yield of triple BBB rated bonds, i.e 120% of 14.39% and adopted interest rate of 17.26% and made adjustment. 29. Adjustment proposed by the TPO was sustained by the DRP. 30. Before us, the learned counsel vehemently stated that the transaction of issue of loan to the AE is undertaken by the assessee in foreign currency i.e US dollars. Therefore, the rate of interest on such loan for the purpose of application of CUP should be considered to be foreign currency lending by unrelated parties which is LIBOR rate of interest. 31. Strong reliance was placed on the decision of the Hon'ble Delhi High Court in the case of Cotton Naturals (I) Pvt Ltd ITA No. 233/2014. 32. Per contra, the ld. DR strongly supported the findings of the TPO and vehemently stated that since the loan was given by an India....
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....ency in which the repayment is to be made. The same principle should apply." 34. The Hon'ble coordinate bench in the case of Everest Kanto Cylinder Limited ITA No. 7073/MUM/2012 for Assessment Year 200809 has also held that rate to be used for undertaking an adjustment should be LIBOR and not the average yield rates. 35. In light of the decision of the Hon'ble Delhi High Court [supra] we find that the LIBOR rate of interest was 5.124% whereas the interest charged by the assessee was 12% per annum. Therefore, we are of the considered opinion that no TP adjustment is required on this transaction. Ground No. 8.3 is allowed. 36. Second part relates to receivables against expenses incurred on behalf of Nice International Inc and LT Overseas Inc. While imputing interest rate of 17.26%, the TPO has also applied the same on the receivables outstanding against routine expenses incurred by the assessee on behalf of its AE. 37. Facts on record show that the assessee has given advance to employees/directors travelling abroad and also facilitated payment of certain expenses on behalf of the AE. The said payment of expenses by the assessee were for a very short period of time and....
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....n relation to a debt created out of loan transaction. 40. There is no dispute that the routine expenses incurred by the assessee in regular course of if its business are considered as loan and in light of ratio of laid down by the Hon'ble Supreme Court [supra] read alongwith OECD guidelines [supra] we do not find any merit in such adjustments and the same are directed to be deleted. 41. Ground No. 8.4 relates to interest on outstanding receivables. During the course of TP assessment proceedings, it was noticed from the invoice-wise details of rice sold to AE that the assessee has received sale consideration after some time lag, beyond the period agreed to between the parties that is 25 days to 120 days. Such details are at pages 24 to 30 of the TPO order. 42. The TPO recharacterised the delay in receipt of receivables as unsecured loans advanced to the AE and imputed notional interest @ 7.26% and, accordingly, proposed adjustment of Rs.28.57 lakhs which was upheld by the DRP. However, the DRP directed the TPO to consider the rate of interest at 12.72% being PLR of interest by SBI. 43. Pursuant to the directions of the DRP, final adjustment was made at Rs. 21,05,962/-. B....
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....ion of the assessee that no interest has been charged from non-AEs on similar delay cannot be brushed aside lightly. In fact, in the case of Aura OI SAS, delay was of 81 days and in the case of Sabi Foods, delay was of 52 days and no interest was charged by the assessee. 49. We have elsewhere mentioned the operating profit margin of the assessee vis a vis comparable companies from where it can be seen that the operating profit margin of the assessee is much higher than that of the comparable companies. 50. Considering the facts in totality in light of the ratio laid down by the Hon'ble Jurisdictional High Court [supra[ and keeping in mind that no interest was charged from receivables from non-AES, we are of the considered view that this adjustment is unwarranted and, accordingly, direct the Assessing Officer to delete the addition of Rs. 21,05,962/-. Ground No. 8.4 is, accordingly, allowed. 51. Ground Nos. 8.5 and 8.6 become otiose. 52. Ground No. 9 relates to denial of deduction u/s 80IB(11A) of the Act amounting to Rs.12,34,19,871/-. 53. Facts on record show that this is not the first year of claim, but, in fact, is the fifth year of claim, which means that this cl....
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....creating infrastructure, therefor. 36. In this context, it is not out of place to note the observations of the Mumbai Bench of the Tribunal in the case of ITO vs. Shankar K. Bhanage: 25 taxmann.com 310, to the effect that the literal interpretation of words "integrated business of handling, storage and transportation of food grains" will not lead to any absurdity or produce any manifestly unjust result; that the Legislative intent is not to encourage transportation or handling of food grains but the Legislative intent is to encourage construction of godowns and warehouses with a view to providing storage of food grains. If we consider the entire combat of the scheme relating to the tax holiday provided by the Legislature, we find that the deductions are available under various provisions when the assessee has contributed something towards the infrastructure development of the country, but the main purpose of bringing this provision is construction of godowns specifically for stocking food grains for greater efficiency in the grain management system and minimize post-harvest food grain losses. XXXXX XXXXX 39. In this context, it is necessary to lo....
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....hem in the markets, and more particularly, avoiding the losses in threshing and winnowing by better mechanical methods, following sanitation during drying, milling and after milling to avoid contamination of grains and protect from insects, rodents and birds, using proper technique of processing i.e. cleaning, parboiling and milling, adopting the grading practices to get more profit and to avoid the economic losses, and using efficient and good packaging for storage, as well as in transportation, by investing more than Rs.30 crores for setting up of the eligible unit and for this purpose advanced machinery with improved technology was installed for efficiently handling food grains and to avoid any post-harvest losses, developed huge storage capacity to handle paddy stock of more than 1,50,000 Metric Ton (MT) and 70,000 MT of rice in order to bring efficiency in the grain management system and incurring significant expenditure to facilitate transportation of food grains by way of acquiring trucks, tractors and trolleys and has also hired trucks for the purposes of carrying food grains from the farmers and mandis to its storage blocks and thereafter to the markets, followed by upgrad....
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....cisely which activities would amount to handling, and when the meaning of handling is a lefty to be interpreted context surely, it is necessary to meet some concreteness on this aspect as against imagination. No doubt the activities enumerated by the Ld. DR too answer the description of handling in the context of food grains under section 80IB(11A) of the Act, is necessary that in order to be eligible to claim the benefits under section 80IB(11A) of the Act, whether the assessee is required to install all such facilities or such facilities at suit the convenience of the assessee while meeting the avowed object of 80IB(11A) of the Act would entitle the assessee to claim such benefit is the mute question. 45. In plain English handling includes any process not amounting to manufacture of the treatment of the product with a view to deal with the 31 same to achieve a desired purpose. In a sense it includes all the activities preparatory and axillary in nature. Merely because the word processing is occurring in 80IB(11A) of the Act in respect of the fruits or vegetables, it does not exclude all the processes from meaning of "handling". As stated supra, there are various steps in....
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....0405 and 2005-06 in which case the deduction under section 80IB(11A) of the Act was allowed to the assessee who was conducting the activities which were identical to the activities conducted by the assessee in the case of Laxmi Energy (supra) and the assessee before us. 49. For that matter, Ld. DR admitted during the course of arguments 39 while dealing with this alternative prayer for remand of the matter to the file of learned Assessing Officer that the facts involved in Laxmi energy (supra) are identical to the facts involved in the case on hand, in respect of the activities of the assessee. It is therefore, clear that the assessees who were conducting the business similar to the one done by the assessee in this case, were found entitled to the benefit under section 80IB(11A) of the Act and such a view is consistent so far. Without mincing many words, while following the ratio of those cases, we are of the considered opinion that the activities involving the cleaning, steaming, soaking, drying, polishing, grinding etc.are covered by the expression "handling" and the assessee is certainly conducting such activities which would entitle to the benefit of deduction under se....
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....arh unit constitutes more than 20%, which according to him means that more than 20% of the machinery had become old prior to 1/4/2001. As a matter of fact, the Assessing Officer could have referred to the schedule of fixed assets or the stock registers or the financials of the assessee to say that none of the missionary that was put to use at Bahalgarh unit for the purpose of the integrated business of handling, storage and transportation of food grains was new and was transferred from the old unit. No such exercise to return a finding the fact was undertaken by the learned Assessing Officer before reaching the conclusion that more than 20% of the machinery at Bahalgarh unit had become old prior to 1/4/2001. 57. Ld. CIT(A), however, made a reference to the quantitative details and considered the contention of the assessee that the entire machinery used the as eligible unit at Bahalgarh was new one and not old machinery was used and observed that the learned Assessing Officer , without mentioning the instances of old plant and machinery being used by Bahalgarh unit, presumed that the plant and machinery for Bahalgarh unit used prior to 1/4/2001 and was transferred such old ....
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....5345 to 5348/DEL/2018. 58. As no distinguishing decision has been brought to our notice by the Revenue, respectfully following the decision of the co-ordinate bench [supra], we direct the Assessing Officer to allow claim of deduction u/s 80IB(11A) of the Act. Ground No. 9, alongwith sub grounds is allowed. 59. Ground No. 10 relates to disallowance made u/s 14A r.w.r 8D of the Rules. 60. During the course of assessment proceedings, it was noticed by the Assessing Officer that the assessee has received income of Rs. 69,40,799/- in respect of which exemption was claimed u/s 10 of the Act. This exempt income comprises of: i) Share of profit in partnership firm M/s Raghunath Agro Industries, Amritsar - Rs. 68,76,452/- ii) Dividend income from investment in mutual funds - Rs. 64,347/- Invoking the provisions of section 14A of the Act r.w.r 8D of the Rules, the Assessing Officer disallowed Rs. 53,26,986/- after deducting suo moto disallowance of Rs. 16,13,813/- by the assessee. 61. In so far as the share of profit from partnership firm is concerned, in Assessment Year 2007-08, this Tribunal in ITA No. 4164/DEL/2013 vide order dated 30.09.2020 has deleted the dis....
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....ngly, allowed. 64. Ground No. 11 relates to addition of Rs. 5,73,775/- made by the Assessing Officer without following the directions of the DRP. 65. Facts before us show that total addition by the assessee has been made to the tune of Rs. 11,86,947/- which comprises of the following: a) Foreign travelling of wives of the directors Rs. 5,73,775/- b) Payment made to Sundari Apparels I. P. Ltd Rs. 50,000/- c) Payment made to Shadi Online Pvt Ltd Rs. 1,25,000/- d) Payment made for taxi bills Rs. 95,948/- e) Payment made to Sycoriam Matrimonial Services Ltd Rs. 1,00,000/- f) Payment made to Health Resort Rs. 1,79,584/- 66. Before us, the ld. counsel for the assessee did not press disallowances/additions referred in (b) to (f) above. Therefore, the same additions referred to in (b) to (f) are confirmed. 67. In so far as the foreign travelling expenses of wives of directors is concerned, we find that the DRP has made the following observations: "We have carefully considered the issue, the reasoning of the AO for making the disallowance and the submissions of the ARs. The expenditure on travel of the wives and the ....
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....ital (P) Ltd. Rs.1,05,19,549 Finance advisory for identifying Target Company 2. Price WaterHouse Rs.12,29,106 Tax and regulatory advise prior to acquisition 3. The Chug Firm Rs.17,62,541 Legal and financial due diligence prior to acquisition 4. Trademark Rs.10,100 Trade mark registration expenses 5. Ernst & Young Rs.15,19,669 Brand valuation expenses 6. Lakshmi Kumaran & Sridharan Rs.19,20,364 Legal advisory on feasibility of acquisition 7. Safron Capital Advisory (P) Ltd. Rs.2,00,000 Valuation reports Revenue Expenditure Total Rs.1,71,61,328 75. The ld. DR strongly supported the findings of the AO/DRP. 76. We have carefully considered the orders of the authorities below. A perusal of the aforementioned bifurcation of expenses shows that the expenses have been incurred on due diligence and advisory report conducted by the professional firms and on the basis of such report/analysis the assessee identified the target company Kusha Inc for acquisition to help expand export sales of the assessee in USA. 77. Facts on record show that the assessee made total export sales of Rs....
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....er the Tribunal was right in allowing the legal expenses of Rs. 15 lakhs incurred towards obtaining advice and by way of consultation fees paid to the auditors of the assessee-company as to the feasibility of acquiring a brewery unit in South Africa 69. As the revenue has not disputed that the assessee had in fact incurred this expenditure and though Sri Seshachala, learned senior standing counsel appearing for the appellantrevenue would bring to our notice the relevant statutory provision, namely, section 35D of the Act as it prevailed at the relevant point of time and submits that any expenditure incurred by way of expansion of business undertaking or in connection with the setting up of new industrial unit etc., is to be amortized as part of the investments, we are not impressed either by the submissions that it is in the nature of 'capital expenditure' or that section 35D of the Act is attracted to the facts of the instant case. 70. We say so for the reason that an expenditure incurred even in connection with acquiring a capital asset which is in the nature of a fee paid towards consultation for the business expansion, as the expenditure incurred may o....
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....pany. A certain number of shares of the new company were allotted to the asses- see in consideration of the transfer of these assets. During the years 1975-76 and 1976-77, interest on borrowings which were made for the purpose of these assets was allowed as business expenditure but a similar claim for deduction during the assessment years 1977-78 and 1978-79 was rejected by the 1TO on the ground that the borrowings were made to create assets which were diverted as the capital of new company L. The Tribunal, however, allowed the claim of the assessee for deduction of interest on the borrowings." 84. The Hon'ble Karnataka High Court held as under: "The Appellate Tribunal was justified in concluding, from the facts and circumstances, that there was no trusteeship in respect of the setting up of the new company by the assessee, and that the expenditure incurred on the setting up of the undertaking (or the unit) to manufacture mica paper was a expenditure incurred by the assessee as part of its existing busies operation. If, for any reason, the Government of India or any statutory authority refused to permit the new company to have the import licence or have the....
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....carefully perused the orders of the authorities below. There is no dispute that the impugned amount was paid as final settlement of the dispute which arose due to infringement of use of trademark Daawat. In our considered opinion, any expenditure incurred by the assessee to protect its trademark in the ordinary course of business is to be allowed as revenue expenditure because it was a commercial expediency on the part of the assessee to have made the said payment to protect unlawful use of its trademark and the same was incurred wholly and exclusively for the purpose of business. We, accordingly, direct the Assessing Officer to allow deduction of Rs. 25,05,233/-. Ground No. 12 along with sub-grounds is allowed. 94. Ground No. 13 with sub grounds relates to the disallowance under section 40(a)(ia) of the Act. 95. The underlying facts in this issue are that the Assessing Officer, during the course of assessment proceedings and on perusal of the financial statements of the assessee, found that the assessee has claimed expenditure of Rs. 2,97,02,201/- on which no tax was deducted at source and further found that on Rs. 18,44,145/- there was a short deduction of TDS. 96. Befor....
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.... We have carefully perused the chart mentioned hereinabove. In so far as freight and labour charges are concerned, the same are reimbursements and in our considered view, there is no liability of TDS on reimbursement of expenses. 100. We have also perused evidences brought on record in the paper book. We find that each payment is below the limit on which tax is not required to be deducted at source. 101. Market development charges have been paid to a non-resident and since the non-resident does not have any PE in India, its income is not taxable in India and, therefore, there is no liability for TDS. 102. Rail freight has been paid to Container Corporation of India and section 194C of the Act does not apply on such payment. 103. Facts on record show that similar disallowance made in Assessment Year 2007-08 was deleted by the ld. CIT(A) and the revenue did not prefer any further appeal. 104. Steamer freight of Rs. 25,91,443/- has been paid to NORASIA Container Lines Ltd, which is a foreign shipping company to which section 172 of the Act applies and, therefore, there was no liability to deduct tax at source. 105. In so far as commission and hotel accommodation char....
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....nd bad in law and the report submitted by the special auditor is illegal, bad in law and without jurisdiction. 5 That the special auditor has erred on facts and in law in scrutinizing and auditing those issues which are not part of the terms of reference and has exceeded his jurisdiction in making observations about those issues in the audit report submitted. 6. That in view of the facts and circumstances of the case and in law the A.O. has erred in completing the assessment U/s 153A/144C at Rs. 29,02,72,968/-/- as against returned income of Rs. 10,65,10,920/- (after disallowing deduction under chapter VIA). The additions made are unjust, unlawful, bad in law, without jurisdiction and are also highly excessive. 7. That in the absence of any incriminating material found during search, the additions made by the AO while completing assessment U/s 153A rws 143(3) are unjust, arbitrary, and bad in law and without jurisdiction. 8. That the reference made to the T P O. is illegal and bad in law and the order passed u/'s 92CA(3) is illegal bad in law and without jurisdiction. 8.1 That in view of the facts and circumstances of the case and in....
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.... law the A.O. has erred in holding that an amount of Rs. 11,24,307/- (Rs. 5,73,775/- + 1,75,000/- + Rs. 1,95,948/- + Rs. 1,79,584/-) is in nature of personal expense. 11.1 That in view of the facts and circumstances of the case and in law the A.O. has erred in law and on facts in not following Ld. D.R.P. directions by not allowing the expenditure of Rs. 5,73,775 - on travel of the wives of the Directors. Disallowance of Revenue Expenditure 12. That in view of the facts and circumstances of the case and in law the A.O./D.R.P. has erred in holding deferred revenue expenditure incurred during the year and claimed as revenue expenditure during the same assessment year as capital expenditure and in not allowing deduction of Rs. 1,96,66,651/- (Rs. 1,71,61,328/- + Rs. 25,05,323/-). 12.1 That in view of the facts and circumstances of the case the AO/D.R.P. has erred in not appreciating that the expenditure incurred of Rs. 1,71,61,328/- for acquiring a subsidiary was in order to facilitate the business and was an allowable business expense as the same is in the nature of business expense. 12.2 That in view of the facts and circumstances of the ca....
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....ount of adjustment in international transactions carried out with AEs. 115. The break-up of the TP adjustment is as under: i) Rs. 9,23,713/- on account of export of goods; ii) Rs. 32,86,303/- on account of arm's length interest on loan to AEs; and iii) Rs. 22,38,036/- on account of interest receivables from AEs. 116. The underlying facts in the impugned issue are that during the year, the assessee has exported rice to its AEs Kusha Inc and Nice International FZE aggregating to Rs. 17745.05 lakhs. The assessee has claimed the said international transactions to be at arm's length by bench marking under both the methods i.e. CUP and TNMM as under: AE/ Non-AE Brands OP/ Sales AE - Kusha (USA) Royal Brand 7.44% OTHER BRAND 7.39% AE - Nice ALL BRAND 20.05% Average 7.48% Non-AE All export 6.35% DOMESTIC RICE (ALL BRANDS) 7.72% Average 7.25% Brands OP/Sales Operating profit margin of appellant 11.86% OPERATING PROFIT MARGIN OF COMPARABLE COMPANIES 9.85% 117. We have carefully perused the facts and found that the facts are pari materia same as are c....
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....allowance made by the Assessing Officer was upheld by the DRP. 125. Before us, the ld. counsel for the assessee stated that in so far as exempt income being share of profit from Raghunath Agro Industries is concerned, the same has been considered in earlier Assessment Years also and no disallowance should be made in so far as this exempt income is concerned. 126. In respect of other exempt income, it is the say of the ld. counsel for the assessee that the Assessing Officer/DRP grossly erred in attributing interest expenditure when the assessee has sufficient own funds to make investment and placed strong reliance on the decision of the Hon'ble Bombay High Court in the case of Reliance Utilities & Power Ltd 313 ITR 340. 127. Per contra, the ld. DR strongly supported the orders of the Assessing Officer. 128. We have given thoughtful consideration to the orders of the authorities below. We have also perused the disallowance made by the Assessing Officer mentioned elsewhere. In so far as exempt income relating to share of profit from Raghuram Agro Industries is concerned, the same was also considered by us in ITA No. 6221/DEL/2012 for Assessment Year 2008-09 vide Ground....
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....ing provisions. Ledger a/c filed before AO/DRP 7 Inland Haulage & BL Charges Rs.4,80,326 Rail Freight charges paid on which no TDS is applicable U/S 194C. 8 Detention Charges Rs.4,66,656 Amount Paid to agent of Foreign Shipping Co. - Section 172 applicable 9 Job work Charges Rs.1,72,500 - 10 Other Expenses - Antenna installation, Annual report posting and handling charges, BAAN Support Fee, Rs.5,61,165 - 11 Courier Rs.75,254 - 12 Marriage event Rs.4,63,232 - 13 services Interest on security deposit Rs.5,805 - Total Rs.2,58,94,147 135. In so far as items at Sl. No. 1 to 9 are concerned, similar issue was considered by us in ITA No. 6221/DEL/2012 for Assessment Year 2008-09 vide Ground No. 13 with sub grounds of that appeal. For our detailed discussion therein, we follow the findings given therein. 136. Expenditure considered in Item Nos. 10 and 11 are set aside to the file of the Assessing Officer. The Assessing Officer is directed to demonstrate that the recipients have show income in their respective return of incomes and the Assessing Officer is directed to examine the same a....
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.... RICE RICE SPL BAS FINISH BWN WANDOT RADERS JOE TIFIED ZAFRANI BASMATI RICE (OLD) BASMATI RICE TOTAL Controlled ANNEXUR ONLY BARTS Amount in Rs. Lecs Unit (Re) Uniti MT Gross Price Unit (Rs.) Unit in MT Gross Price Price per Unit (Rs.) [Unit in Prico MT Gross Price Unit (R 35.804 452 236 52.228 55 25 345 2,973 26.10 14.05 167.71 1.200.67 47,087 59 27.65 46.529 25 14.65 50.011 3 1.16 38,548 11 50,377 44,860 8,439 3.355 61 52.114 48,618 40,383 3.425 3 6,464 345 167.71 48,619 1,436.72 1.16 3,367.94 41,945 38.548 558 249.75 44,798 249.75 44,798 THO 297.03 40,280 740 287.03 40,220 120 84.57 70.477 120 84.57 70.477 20 9.56 47,810 20 9.56 80 45.84 57,366 80 45.84 $7.360 230 108.34 47.045 230 108.34 47,041 83 41 64,516 41 51,196 63 40.65 04511 5,448 2,503.64 45.972 5,446 2.503.64 45,97 80 126 280.80 71.01 45,627 56,360 125 41 260.80 71.01 51,10 616....
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....,157 34,776 2.455 919.11 37,446 2.567 965.01 37,309 27.822 48.59 33.887 167 55.27 33,017 306 126.60 41,320 306 126.60 41.320, 442 149.54 33,833 442 149.54 33.833 945 354.73 37,542 945 354.73 37.542 85 43.38 45,504 95 43.38 45,504 387 93.59 387 $3.59 24,186 230 94.39 41,038 230 54.39 41,038 574 250.71 43.648 574 250.71 43.648 8.75 24,311 6.75 24.3:1 56 18.81 33.588 56 18.61 22. 36 8.77 24,359 36 6.77 80 32.26 40.528 80 32.20 24 8.00 38,147 24 5.68 1.383 457.50 33,082 1,383 457.59 30 17 33.082 753 243.05 32,272 753 43.05 32,272 3,294 969.59 29,440 3,294 969.59 29,440 INDIAN SUPER BRW BAS RICE 07 1,008 431.79 42 637 1,000 431.79 42,837 200 COP MAHDANE BRAND MANI GOLDEN MOHSEN HOUSE WIFE SELLA NONAME BASMATI RICE ORANGE PREMIUM RICE PRESIDENTS CHOICE BASMATI RICE RICE A GD PARBOILED BROWN 2007 RICE A GRADE FINISH BWN WAND06 RICE A GRADE FINISH ....