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1984 (4) TMI 89

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....of Rs. 11,449 and Rs. 11,150 for the two years under appeal for the Sewri Property, disallowance of interest of Rs. 2,798 and Rs. 2,104 in respect of the same property and non-allowance of certain expenses in respect of the Poona Property. The other grounds of appeal are not pressed. 2. In respect of the Sewri Property, the assessee claimed collection charges of Rs. 11,449 and Rs. 11,150 for the....

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....erall payment made to the Trustee was allocated between the property income and the business income, the former being restricted to 6% on the basis of collection charges and the balance allowed for business. The position continues and there was no change. According to the ld. counsel, when the Department has accepted the liability to allow the deductions for all years, there was nothing new which ....

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....the claim of the assessee. That an actual payment is made to the Manager of the Trust having properties and business is not disputed. In the past an allocation has been made between the property and business income. The extent of activity performed by the Manager for the business and for the property may not perhaps be very accurately computed but it cannot be denied that between the two the overa....