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that the assessee knew all along that the claim it was making was inaccurate.

9.4. The Learned Assessing Officer has concluded in the last paragraph of the order as under.-

"I therefore hold that the assessee has deliberately and consciously furnished inaccurate particulars of income and attempted to conceal income to the tune of Rs. 59,48,810/-"

9.5 We respectfully submit before your honor that the Learned Assessing Officer- has not concretely held that the appellant has concealed any income and rather has observed that he has deliberately and consciously furnished inaccurate particulars of income. In this respect we' would also like to submit before your honor that the appellant has correctly submitted an particulars of income viz. the nature, source and quantum, which has not been disputed by the Learned Assessing Officer. The addition to the total income is by way of disallowance of a claim Vis. 24(b) of the Act. This claim has been disallowed on the basis of a different method of calculation under a different head of income adopted by the Learned Assessing Officer. This amounts to a different interpretation of law leading to a different method of calculating the appellant's income from the same particulars submitted by the appellant. Hence we respectfully submit that there is no concealment/furnishing of inaccurate particulars of income by the appellant company and consequently the decision of honorable Apex Court in the case Reliance Petroproducts and Delhi High Court in the case of Zoom developers is squarely applicable in favor of the appellant.