1980 (9) TMI 105

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....nder s. 147(b) in order to include a sum of Rs. 3,344 on account of betterment tax allowed in the original assessment. While completing the assessment the ITO not only disallowed the sum of Rs. 3,344 but also added a sum of Rs. 18,573 representing bank guarantee commission. On appeal the AAC upheld the reopening of the assessment and also the additions. It is against this order that the present ap....

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....e bank was to guarantee for the payment of the above amount being the purchase price to be paid over a period on instalment basis on payment of a particular guarantee commission. The interest paid on the loan was allowed by the ITO but not the guarantee commission. The commission amount was treated by him as forming part of the cost of the machinery. 4. On going through the facts we find that t....