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“Income-tax Officer”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(25) / Section 1175,006 judgments

The decision most relied on for Income-tax Officer is CIT v. Max India Ltd. (295 ITR 282), cited in 1,162 judgments on BharatTax.

Leading authorities on Income-tax Officer

CIT v. Max India Ltd.
295 ITR 282 · 2007 · Supreme Court
1,162
citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Dhakeshwari Cotton Mills Ltd. v. CIT
26 ITR 775 · 1954 · Supreme Court
1,061
citing judgments

Corroborative evidence is essential to support evidence found on third-party premises, and an assessment cannot be based on suspicion, surmises, or conjecture.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

CIT v. Kanpur Coal Syndicate
53 ITR 225 · 1964 · Supreme Court
359
citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

Paul Mathews & Sons. v. CIT
263 ITR 101 · 2003 · High Court
266
citing judgments

A statement recorded under Section 133A of the Income-tax Act has no evidentiary value because Section 133A does not empower an Income-tax Officer to examine any person on oath.

Navnitlal C. Javeri v. K.K. Sen
56 ITR 198 · 1965 · Supreme Court
230
citing judgments

The Supreme Court holds that circulars issued by the Central Board of Direct Taxes (CBDT) are binding on all officers and persons employed in the execution of the Income-tax Act. These circulars are binding even if they deviate from the provisions of the Act, particularly when issued to relieve hardships.

Judgments citing Income-tax Officer

Allahabad Bank Now Indian Bank, Panchkula vs. Deputy Commissioner of Income Tax (TDS Circle), Panchkula

In the result, the appellant's appeal is DISMISSED

ITA 292/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh16 Dec 2024AY 2015-16

Bench: Shri Vikram Singh Yadav & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 292/Chd/2024 "नधा"रण वष" / Assessment Year: 2015-16 Allahabad Bank, Vs. The Dcit बनाम (Tds Circle), Now Indian Bank Panchkula Sco 12A, Sector 11, Panchkula "थायी लेखा सं./Pan No: Rtka02368C अपीलाथ"/ Assessee ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri U.S. Aggarwal, Advocate & Shri Manuj Bansal, Ca राज"व क" ओर से/ Revenue By : Shri Shakti Singh, Jcit Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 19.11.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 16.12.2024 आदेश/Order

For Appellant: Shri U.S. Aggarwal, Advocate &For Respondent: Shri Shakti Singh, JCIT Sr. DR
Section 201Section 246ASection 249(3)Section 250Section 253

mentioned wrong FY and AY while filing form 35 which also reflects its casual attitude. 4.3 In the case of Satbarg Singh v. Income-tax Officer, Ward- 2 (3), Chandigarh [2015] 61 taxmann.com 46 (Chandigarh - Trib.), it was held that in condoning the delay the appellate authority must be satisfied

Kandaiah Muthukrishnan, Chennai vs. Dcir, CC-2(4), Chennai

The appeal stands allowed in terms of our above order

ITA 1214/CHNY/2024[2020-21]Status: DisposedITAT Chennai16 Dec 2024AY 2020-21

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1214/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2020-21) Shri Kandaiah Muthukrishnan Dcit बनाम/ #161, Rangarajapuram Main Road, Central Circle-2(4) Vs. Kodambakkam, Chennai-600 024. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aftpm-5826-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri G. Baskar (Advocate)- Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 03-12-2024 घोषणा की तारीख /Date Of Pronouncement : 16-12-2024

For Appellant: Shri G. Baskar (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 132Section 142(1)Section 143(3)Section 263

consequence of an order of the Assessing Officer cannot be treated as prejudicial to the interest of the revenue. For example, when an Income-tax Officer adopted one of the courses permissible in law and it has resulted in loss of revenue; or where two views are possible ... Income-tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interest of the revenue, unless the view taken by the Income-tax Officer is unsustainable in law. The said principal has been reiterated

Damji J Gala, Khandilkar Road vs. ITO 19(1)(4), Tardeo Road

In the result the appeal filed by the assessee stands partly

ITA 3407/MUM/2024[2010-11]Status: DisposedITAT Mumbai16 Dec 2024AY 2010-11

Bench: Smt Beena Pillai & Shri Prabhash Shankar

Section 147Section 148Section 2Section 2(47)

which held that once an assessment is validly reopened, the previous under assessment is set aside and the Income-tax Officer has the jurisdiction and duty to levy tax on the entire income that had escaped assessment during the previous year. The Court held that the object of section

Nimit Gupta, Sonipat vs. ITO Ward - 3, Sonipat

Appeal is allowed for statistical purposes in above terms

ITA 3614/DEL/2024[2014-15]Status: DisposedITAT Delhi16 Dec 2024AY 2014-15

Bench: Shri Satbeer Singh Godaraassessment Year: 2014-15

Section 144Section 147

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2014-15 Nimit Gupta, Vs Income-tax Officer, S/o Rajesh Kumar, Ward-3, Sonipat. E-22, Industrial Area, Sonipat-131001. PAN: APMPG 4525 K APPELLANT RESPONDENT Assessee represented by Shri Navin Gupta

Mani Rai, Ghaziabad vs. Income Tax Officer, Ward 2(4) Gurgaon, Gurgaon

Appeal is allowed for statistical purpose in above terms

ITA 3611/DEL/2024[2011-12]Status: DisposedITAT Delhi16 Dec 2024AY 2011-12

Bench: Shri Satbeer Singh Godaraassessment Year: 2011-12

Section 144

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2011-12 Mani Rai, Vs Income-tax Officer, H. No. 01/D1, Tower-1, GH-7, Ward-2(4), Gurgaon. Chipiyana, Crossing Republic, Ghaziabad-201016. PAN: AXCPR 7299 D APPELLANT RESPONDENT Assessee represented

Raj Kumari Agarwal, Ghaziabad vs. ITO, Ward 2(2)(2), Ghaziabad

Appeal is allowed for statistical purposes in above terms

ITA 118/DEL/2024[2012-13]Status: DisposedITAT Delhi16 Dec 2024AY 2012-13

Bench: Shri Satbeer Singh Godaraassessment Year: 2012-13

Section 144oSection 147Section 250(6)Section 69

TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2012-13 Raj Kumari Agarwal, Vs Income-tax Officer, 61, Navyug Market, Ward-2(2)(2), Ghaziabad. Ghaziabad-201001. PAN: AEYPA 7801 F APPELLANT RESPONDENT Assessee represented by None Department represented by Shri

Jitender Kumar, Greater Noida vs. ITO Ward 1(5), Noida

Appeal is allowed for statistical purpose in above terms

ITA 111/DEL/2024[2008-09]Status: DisposedITAT Delhi16 Dec 2024AY 2008-09

Bench: Shri Satbeer Singh Godaraassessment Year: 2008-09

Section 143(3)Section 147Section 68

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2008-09 Jitender Kumar, Vs Income-tax Officer, H. No. 151, Village Ladpura, Ward-1(15), Noida. Post Maincha Greater Noida, U.P.-201301 PAN: AOOPK 4133 Q APPELLANT RESPONDENT Assessee represented

Ravindra Kumar, New Delhi vs. ITO Ward 2(3)(5), Ghaziabad

Appeal is allowed

ITA 400/DEL/2023[2012-13]Status: DisposedITAT Delhi16 Dec 2024AY 2012-13

Bench: Shri Satbeer Singh Godaraassessment Year: 2012-13

Section 144oSection 148

very serious issue of jurisdiction of the Assessing Officer i.e. learned Income Tax Officer, 2 Ward2(3)(5), Hapur; and that of Income-tax Officer, Ward 2(2), Ghaziabad for assessing the assessee in two separate assessment in assessee’s case. 3. Learned counsel refers to the assessee’s supporting ... evidence available in the case file wherein it was the Assessing Officer i.e. Income-tax Officer, Ward-2(2), Ghaziabad, who had in fact initiated section 148 proceedings for the very assessment year against him and dropped the same on 30.09.2019. This being the clinching case, which remains unrebutted from

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Cholan Auto Finance, Karur

In the result, both the appeal of the Revenue in ITA

ITA 1192/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

For Appellant: Shri N.V.Balaji, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar
Section 132Section 143(3)Section 154

made on the right person. Extract from the judgement is reproduced below: “....We are of the opinion that under the present Act, the Income-tax Officer has no option like the one he had under the 1922 Act. He can,and_ he must, tax the right person and the right

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Cholan Auto Finance, Karur

In the result, both the appeal of the Revenue in ITA

ITA 1191/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

For Appellant: Shri N.V.Balaji, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar
Section 132Section 143(3)Section 154

made on the right person. Extract from the judgement is reproduced below: “....We are of the opinion that under the present Act, the Income-tax Officer has no option like the one he had under the 1922 Act. He can,and_ he must, tax the right person and the right

Cholan Auto Finance, Karur vs. Deputy Commissioner of Income Tax, Central Circle 2, Trichy, Tiruchirappalli

In the result, both the appeal of the Revenue in ITA

ITA 1156/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

For Appellant: Shri N.V.Balaji, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar
Section 132Section 143(3)Section 154

made on the right person. Extract from the judgement is reproduced below: “....We are of the opinion that under the present Act, the Income-tax Officer has no option like the one he had under the 1922 Act. He can,and_ he must, tax the right person and the right

Cholan Auto Finance, Karur vs. Deputy Commissioner of Income Tax (Central Circle 2), Trichy, Tiruchirappalli

In the result, both the appeal of the Revenue in ITA

ITA 1155/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकरअपीलसं./Ita Nos.1155 & 1156/Chny/2024 िनधा"रणवष"/Assessment Year:2018-2019 M/S. Cholan Auto Finance, Vs. The Deputy Commissioner Of Income Tax, 43, Padma Tower, 3Rd Floor, Central Circle 2, Covai Road, Trichy. Karur 639 002. आयकरअपीलसं./Ita Nos.1191 & 1192/Chny/2024 िनधा"रणवष"/Assessment Year:2018-2019 The Assistant Commissioner Of M/S. Cholan Auto Finance, Income Tax, 43, Padma Tower, 3Rd Floor, Vs Central Circle 2, . Covai Road, Trichy. Karur 639 002. [Pan : Aagfc 1043B] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri N.V.Balaji, Advocate Department By : Shri. R. Clement Ramesh Kumar, Irs, Cit. सुनवाईक"तारीख/Date Of Hearing : 23.10.2024 घोषणाक"तारीख/Date Of Pronouncement : 13.12.2024 आदेश /O R D E R Per Bench: These Cross Appeals Are Arising Out Of The Orders Of The Commissioner Of Income Tax (Appeals) – 19, Chennai [Hereinafter

For Appellant: Shri N.V.Balaji, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar
Section 132Section 143(3)Section 154

made on the right person. Extract from the judgement is reproduced below: “…..We are of the opinion that under the present Act, the Income-tax Officer has no option like the one he had under the 1922 Act. He can,and he must, tax the right person and the right

Ashwin S. Mehta (Legal Heir of Late Rasila S. Mehta), Mumbai vs. ACIT, CC- 4(1), Mumbai

Appeal is allowed for

ITA 295/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Dec 2024AY 2020-21

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Shri Dharmesh ShahFor Respondent: Dr. P. Daniel (Spl. Counsel for the Department)
Section 142(1)Section 143(2)Section 143(3)Section 234BSection 250Section 3(2)Section 68

jurisdiction, under section 31(3) of the Act, to assess a source of income which has not been processed by the Income-tax Officer and which is not disclosed either in the returns filed by the assessee or in the assessment order, and therefore the Appellate Assistant Commissioner cannot travel ... restricted to the subject-matter of assessment or the source of income which have been considered expressly or by clear implication by the Income-tax Officer from the point of view of the taxability of the assessee.” 10. Reference was also made to the similar findings rendered

Yogesh Ginning Mill, Prop. Yogesh Chand Gupta, Govindgarh vs. ACIT, Circle I, Alwar

In the result, the appeals filed by the assessee are allowed

ITA 540/JPR/2024[2018-19]Status: DisposedITAT Jaipur12 Dec 2024AY 2018-19

Bench: This Tribunal Which Were Passed By The Commissioner Of Income Tax (Appeal)- 4, Jaipur [ For Short Cit(A) ] Passed On Dates & F For The Assessment Years Mentioned As Tabulated Here In Below, In Turn Those Orders Were Arises Because The Assessee Has Yogesh Ginning Mill Vs. Acit

For Appellant: Shri Paridhi Jain, AdvFor Respondent: Shri Gajendra Singh (Addl.CIT) a
Section 143(2)Section 143(3)Section 145(3)Section 250Section 68

that where an assessee fails to prove satisfactorily the source and nature of certain amount of cash received during the accounting year, the Income-tax Officer is entitled to draw the inference that the receipts are of an assessable nature In the case of Kale Khan Mohammad Hanif v. Commissioner ... Mill vs. ACIT it was, it was exempt from taxation under the provisions of the Act. In the absence of such proof, the Income-tax Officer is entitled to treat it as taxable income: see A Govindarajulu Mudaliar v. Commissioner of Income-tax

Yogesh Ginning Mill, Prop. Yogesh Chand Gupta, Govindgarh vs. ACIT, Alwar

In the result, the appeals filed by the assessee are allowed

ITA 1045/JPR/2024[2017-18]Status: DisposedITAT Jaipur12 Dec 2024AY 2017-18

Bench: This Tribunal Which Were Passed By The Commissioner Of Income Tax (Appeal)- 4, Jaipur [ For Short Cit(A) ] Passed On Dates & F For The Assessment Years Mentioned As Tabulated Here In Below, In Turn Those Orders Were Arises Because The Assessee Has Yogesh Ginning Mill Vs. Acit

For Appellant: Shri Paridhi Jain, AdvFor Respondent: Shri Gajendra Singh (Addl.CIT) a
Section 143(2)Section 143(3)Section 145(3)Section 250Section 68

that where an assessee fails to prove satisfactorily the source and nature of certain amount of cash received during the accounting year, the Income-tax Officer is entitled to draw the inference that the receipts are of an assessable nature In the case of Kale Khan Mohammad Hanif v. Commissioner ... Mill vs. ACIT it was, it was exempt from taxation under the provisions of the Act. In the absence of such proof, the Income-tax Officer is entitled to treat it as taxable income: see A Govindarajulu Mudaliar v. Commissioner of Income-tax

Finesse Jewels Private Limited, Jaipur vs. Deputy Commissioner of Income, Circle 1, Jpr, Jaipur

In the result, the appeal of the assessee is partly allowed

ITA 1249/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Dec 2024AY 2012-13

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalfinesse Jewels Private Limited, A-467 Jaipur, Vidhyut Nagar, Jaipur, Ajmer Road- 302 021. Pan No.: Aabcf 4438R ..... Appellant Vs. Dcit, Circle-1, Jaipur – 302 021. ..... Respondent

For Appellant: Mr. Mukesh Kumar Sharma, Adv., Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, JCIT, DR
Section 143(3)Section 250Section 271(1)(c)

these ingredients which have to be satisfied by the assessee. Mere furnishing of the particulars is not enough. The enquiry of the Income-tax Officer revealed that either the assessee was not traceable or there was no such file and, accordingly, the first ingredient as to the identity ... transactions were through the bank account, accordingly, it is to be presumed that the transactions were genuine. It was not for the Income-tax Officer to find out by making investigation from the bank accounts unless the assessee proves the identity of the creditors and their creditworthiness. Mere payment

Discover Urjaa Charitable Trust, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

The appeal is allowed

ITA 5538/MUM/2024[-]Status: DisposedITAT Mumbai11 Dec 2024

Bench: Justice (Retd.) C.V. Bhadang & Shri B R Baskaran: A.Y. : -

For Appellant: Shri Haridas BhattFor Respondent: Shri R.R. Makwana, Sr. DR
Section 11Section 80G

trust. Hence this objection also cannot be sustained, it follows that the exemption granted by the 5 Discover Urjaa Charitable Trust Income-tax Officer was not erroneous and did not require to be reviewed by the JN Tata Endowment for the Higher Education of Indians, Mumbai Commissioner. Hence his order

Dhule Jilha Prathamik Shikshakanchi Sahakari Patpedhi Ltd Dhule, Dhule vs. Income Tax Officer Ward 1 Dhule, Dhule

In the result, appeal of the assessee is partly allowed

ITA 2185/PUN/2024[2017-18]Status: DisposedITAT Pune10 Dec 2024AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2185/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Dhule Jilha Prathamik V The Income Tax Officer, Shikshakanchi Sahakari S Ward-1, Dhule. Patpedhi Ltd., Plot No.3. Abhiyanta Nagar, Wadibhokar Road, Dhule – 424002. Pan: Aabtd7183N Appellant/ Assessee Respondent / Revenue Assessee By Shri Shirude M.R. – Ar Revenue By Shri Manish Mehta – Addl.Cit(Dr) Date Of Hearing 05/12/2024 Date Of Pronouncement 10/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2017-18 Dated 05.09.2024 Passed U/Sec.250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. In These Facts, Circumstances & Position Of Law Assessment Order Under Appeal Is Bad In Law Illegal & Void Ab Initio & Hence May Be Annulled.

Section 250Section 80PSection 80P(2)(a)

ITAT Pune Bench in the case of Kolhapur District Central Co-op. Bank Kanista Sevakanchi Sahakar Pat Sanstha Ltd. Vs. Income-tax Officer 158 taxmann.com 322 (Pune Tribunal) has held as under : Quote “7………………………..I am of the considered opinion that even the interest income earned by cooperative society

Allcargo Gati Limited(Formally Known As Gati Limited), Hyderabad vs. ITO, Ward-2(2), Hyd, Hyderabad

In the result, the appeal of assessee in ITA

ITA 190/HYD/2016[2010-11]Status: DisposedITAT Hyderabad10 Dec 2024AY 2010-11

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Madhur Agarwal, AdvocateFor Respondent: Ms. K. Haritha, CIT-DR
Section 36(1)(iii)Section 37Section 37(1)

years which was the period of redemption and dividing the amount of Rs.3 lakhs over the period of 12 years. The Income-tax Officer disallowed the claim but the appellate Assistant Commissioner allowed the deduction of Rs.12,500. The Tribunal held that the entire expenditure of Rs.3

Allcargo Gati Limited(Formally Known As Gati Limited), Hyderabad vs. ACIT, Circle-2(2) Hyderabad, Hyderabad

In the result, the appeal of assessee in ITA

ITA 1721/HYD/2016[2012-13]Status: DisposedITAT Hyderabad10 Dec 2024AY 2012-13

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Madhur Agarwal, AdvocateFor Respondent: Ms. K. Haritha, CIT-DR
Section 36(1)(iii)Section 37Section 37(1)

years which was the period of redemption and dividing the amount of Rs.3 lakhs over the period of 12 years. The Income-tax Officer disallowed the claim but the appellate Assistant Commissioner allowed the deduction of Rs.12,500. The Tribunal held that the entire expenditure of Rs.3