adverse observations regarding
the assessee's accounts for financial year 2005-2006 as well including specific
observations relating to closing stock. The auditors ... observations did not affect the taxable income of the
assessee, the assessee having provided detailed explanations against each of
the observations of the auditors along
Advisory Pvt. Ltd. had infused funds in SG Group
Companies. The Auditor‟s observation is that the ADAG Companies had
repaid the loans during ... Advisory
Services Ltd. in SG Group Companies, the report of the Auditor observed
that OCDs were issued to Reliance Capital Advisory Services Pvt. Ltd.,
however
available in
the accounts without any detail. When the observation of Special
Auditor contained at pages No. 10 - 19 were confronted to the assessee ... that AO on the strength of observation made by the
Special Auditor has observed that assessee failed to reconcile the
amount
special audit report
part-1 at para 3.5 the auditors observed as under:
"3.5 Year wise details of reconciliation of cash
payment ... Again, at page 164 para 3.1 of the audit report, the
auditors observed as under:
"3.1 From the perusal of such verification
separate PAN nos, therefore the special auditor has
made certain observations on the basis of wrong facts. Even it has been
observed in para ... case of
balance sheet and profit & loss account. This observation of the special
auditor is contrary or contradictory to its opinion that proper Books
separate PAN nos, therefore the special auditor has
made certain observations on the basis of wrong facts. Even it has been
observed in para ... case of
balance sheet and profit & loss account. This observation of the special
auditor is contrary or contradictory to its opinion that proper Books
Assessing Officer
on the basis of the report of the special auditor observed that
commission expenses of Rs.8,56,111/- claimed pertaining to
booking ... Assessing Officer on the basis of report of the special auditor,
observed that payments of Rs.1,18,36,835/- have been made
action taken by the respondents is in conformity with the CAG
observations.
24. The learned counsel for the respondents further submits that ... including a constitutional body like the
Comptroller and Auditor General (CAG), draws conclusions or makes
observations in a report that adversely affect the rights, reputation
action taken by the respondents is in conformity with the CAG
observations.
24. The learned counsel for the respondents further submits that ... including a constitutional body like the
Comptroller and Auditor General (CAG), draws conclusions or makes
observations in a report that adversely affect the rights, reputation
allocation of overheads.
126. Ld. Assessing Officer based on Special auditor‟s observation
noted that there were certain discrepancies with regard to
apportionment of common ... after observing and holding as under:
"9.8 I have considered the submission of appellant, observation of the
ASSESSING OFFICER & Special Auditors comments, decision
