Dy. Commissioner Of Income Tax, Circle- ... vs Synbiotics Ltd., Vadodara on 31 October, 2023
Secondly, it
is also observed that the assessee had furnished copies of secondment letters
on sample basis before the assessing officer for his verification. The contents
of the aforesaid secondment letters have not been disputed by the assessing
officer. Accordingly, in our considered view, the assessee has reasonably
discharged its onus, wherein copies of secondment letters were furnished
before the assessing officer for his verification. Further, the matter being
very old pertaining to assessment year 1994-95, it would not be possible for
the assessee to produce complete records, especially in the light of the fact
that during the impugned year under consideration the records of the
I.T.A No. 441/Ahd/2022 & CO 35/Ahd/2022 A.Y. 1994-95 Page No. 26
Synbiotics Ltd. vs. DCIT
assessee were destroyed owing to floods. Accordingly, looking into the facts
of the instant case, in our considered view, the aforesaid addition with
respect to secondment of employees to the assessee company, deserves to be
deleted.