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Showing contexts for: Intermediate Act in Aquasoil Canadian Feeds Ltd.,, Baroda vs Department Of Income Tax on 30 August, 2007Matching Fragments
7. The assessee was askea1 to give details during the assessment proceedings but instead of giving details to show evidence regarding commencement of business it has only filed copy of resolution. There is no evidence on the actual conduct of money lending activity, In fact from the Directors report it will appear that company is considering alternatives for manufacturing business and financing only an intermediate act of parking its available funds. During the year company has advanced money only to one single party which can hardly be conceived as business activity. Further assessee has claimed foreign travel expense of Rs.4,31,250/- which can hardly be considered as having spent for earning business income from single loan. No further clarification has been put forth during the course of fresh assessment proceedings. This too was the position during its appellate journey upto the Income Tax Appellate Tribunal which turned out to be futile attempt on the part of the assessee, as it could not establish or satisfy with sufficient evidence that the company has carried out business activity of financing and thereby earned interest Income.