2009 (8) TMI 53

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....elay condoned, subject to just exceptions. Heard on merits. 2. This appeal has been preferred by the assessee under Section 260A of the Income Tax Act, 1961 (for short, "the Act") against order dated 22.9.2006 of the Income Tax Appellate Tribunal, Delhi Bench-B, New Delhi in I.T.A. No.1905 (Del) of 2003 for the assessment year 1992-93, proposing to raise following substantial questions of law:-....

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....sions of section 68 of the Act because section 68 is about receipt of money by any assessee and the same is not about any payments. My attention has been invited to the affidavits of all the persons receiving the chit amounts which have been filed during appellate proceedings and which affidavits have already been taken on record. It has been pointed out that all these persons who have received th....

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....pt of money too from the persons who have contributed to the chits was not in doubt." 4. The Tribunal accepted the appeal of the revenue by observing:- "2.10. Coming to the other payments, it is found that the cheques were drawn in favour of Shri Suresh Chand Gupta and not in favour of the respective chit holders. This did not amount to any payment to the chit holders at all. Therefore, the ....

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....er, if the money involved in the expenditure is appropriated by its, as payment to directors has already been held to be payment to self, then, no expenditure can be said to have been incurred. Therefore, were are of the view that the ld. CIT(A) erred in deleting the addition of Rs.06,63,650/- without discussing the matter in detail by merely mentioning that he found sufficient force in the submis....