FACTS:
The assessee-firm derived its income
from profession as an advocate. In the profit and loss account, the
assessee-firm credited certain amount received as licence fee and compensation
for use of shared facilities.
In the course of assessment, the
Assessing Officer opined that since the aforesaid income was not a professional
income, the same could not form part of 'book profit' for computation of
allowable remuneration to partners under section 40(b).
Issue involved:
• The question came up for consideration was as to
whether for the purpose of computation of allowable remuneration to
partners, the 'book profit' comprises the entire net profit as shown in
the profit and loss account or only profit and gains of business
assessed under Chapter IV-D of the Act.
HELD:
Under clause (v) of section 40(b)
read with Explanation 3, the remuneration allowable to working partners
up to Rs. 50,000 is fully allowable in the hands of the firm. In case the
aggregate payment exceeds the limit of Rs. 50,000, certain monetary limits have
been prescribed under section 40(b)(v) in the form of a
percentage of 'book profit'. For the purposes of this clause, according
to Explanation 3, the book profit means the net profit (as shown in the
profit and loss account for the relevant previous year, computed in the
manner laid down in Chapter IVD) as increased by the aggregate amount of
the remuneration paid or payable to all the partners of the firm if
such amount has been deducted while computing the net profit.
The said chapter nowhere provides that net
profit should be the only income from business or profession alone and
not from other sources. Section 29 provides how the income from profits
and gains of business or profession should be computed and this has to
be done as provided under sections 30 to 43D. Thus for the purpose of
section 40(b)(v) read with Explanation there cannot be
separate method of accounting for ascertaining net profit and/or book
profit. In other words, according to the said Explanation 'book profit'
means the net profit as shown in the profit and loss account including
income from other sources and not only the profit computed under the
head profit and gains of business or profession.
For the reasons as discussed above it is
opined that even if the income from other sources is included in the
profit and loss accounts to ascertain the net profit qua book
profit for computation of the remuneration of the partners the same
cannot be discarded.
Thus, the Commissioner (Appeals) was not justified in upholding the
order of the Assessing Officer in excluding the other income i.e.
compensation for use of shared facilities and license fees from the
'book profit' for the purpose of partners remuneration.
IN THE ITAT MUMBAI BENCH 'J'
Suresh A. Shroff & Co.
v.
Joint Commissioner of Income-tax 11 (3)*
DINESH KUMAR AGARWAL, JUDICIAL MEMBER
AND N.K. BILLAIYA, ACCOUNTANT MEMBER
IT Appeal No. 4140 (Mum.) of 2008
[Assessment year 2005-06]
SEPTEMBER 7, 2012
Ms. Arti Vissanji for the Appellant. Mohit Jain for the Respondent.
ORDER
Dinesh Kumar Agarwal, Judicial Member - This appeal
preferred by the assessee is directed against the order dated
21.04.2008 passed by the ld. CIT(A) for the A.Y. 2005-06.
2. Briefly stated the facts of the case are that
the assessee firm derives income from profession as an Advocate on
record of the Hon'ble Supreme Court of India. The return was filed
declaring total income of Rs. 90,27,232/-. During the course of the
assessment, on examination of the profit and loss account, it was
observed by the A.O. that the assessee has credited a sum of Rs.
30,00,000/- as other income which comprises of (i) Compensation for use
of shared facilities of Rs.10,00,000/- and (ii) License fees of Rs.
20,00,000/-. The A.O. further observed that while computing the
remuneration payable to the partners u/s.40(b) of the Income Tax Act,
1961 (the Act), the assessee has included the above sum of Rs.
30,00,000/- in the book profit. The assessee was asked to explain as to
why the other income of Rs. 30,00,000/- be not reduced for computing the
book profit. In response, the assessee stated that "the amount is
received from M/s. Amarchand and Mangaldas and Suresh A Shroff and
Company for use of name /license fee and use of assets. The word other
income does not mean that it is income from other sources, but the same
is not a receipt as professional fees. We as a auditor use the term as
other income and the same is taxable under the head business and
profession and it is to be considered as part of Chapter IV D income."
It was further observed by the A.O. that as per agreements dated
01.04.2002 entered into between the assessee and the licensee, the
assessee received compensation/license fee of Rs. 30,00,000/- for
sharing the assets and as user of premises. According to the A.O. the
compensation/license fees are not received for rendering any
professional services, therefore, these receipts cannot be considered as
professional income. The A.O. further observed that the assessee, in
his letter dated 30.11.2007 has also stated that "but the same is not a
receipt as professional fees." According to the A.O. since the assessee
himself has admitted that this is not professional income, the same
cannot form part of 'book profit' for computation of allowable
remuneration to partners u/s.40(b) of the Act. Therefore, the A.O.
treated the other income of Rs. 30,00,000/- as assessee's income from
other sources u/s.56 of the Act, and consequently he reduced the same
from the 'book profit' for the purpose of section 40(b) of the Act and
allowed remuneration to partners at Rs. 41,76,580/- as against
Rs.53,76,580/- claimed by the assessee firm. Accordingly, he completed
the assessment at an income of Rs. 1,02,27,240/- vide order dated
26.12.2007 passed u/s.143(3)(ii) of the Act.
3. On appeal, the ld. CIT(A) observed that from the
nature of receipts, it cannot be concluded that the same has any nexus
with the professional activities carried out by the assessee. He further
observed that it is not the business or the profession of the assessee
to share the business assets with others as a business or a professional
activity neither the licence fee is being received for rendering any
such professional activity. It is more akin to leasing activity rather
than a professional activity and such income though not in the strict
sense a lease rent would be taxable under the residuary head of Other
Sources as it would not fall either under the head House Property or
business/profession income and accordingly he held that the A.O. was
justified in excluding such income for the purposes of working out the
remuneration payable to working partners in terms of section 40(b) of
the Act, and, hence, upheld the order passed by the A.O.
4. Being aggrieved by the order of the ld. CIT(A),
the assessee is in appeal before us taking the following revised grounds
of appeal:
"1. The Learned Commissioner of Income Tax (Appeal)
erred in treating amount received for name license fees of Rs. 20 Lakh
as Income from Other Source instead of Income from Business.
2. The Learned Commissioner of Income Tax (Appeal)
erred in treating amount of Rs. 10 Lakhs received on account of shared
Assets as Income from Other sources instead of income from Business.
3. The Learned Commissioner of Income Tax (Appeal)
failed to appreciate that the name license fee and shared assets amount
had been consistently assessed under the head Business since the last 10
years and therefore ought to have been assessed as Business Income
following Supreme Court judgment in case of
Radhasoami Satsang v. Commissioner of Income Tax reported in 193 ITR Page 321.
5. Alternate to ground above learned CIT has not
appreciated that the tax on salary allowed to the firm has been paid by
the partner personally hence there is no loss of revenue either to the
Assessee or to the department."
5. At the time of hearing the ld. Counsel for the
assessee after referring certain clauses of agreements dated 01.04.2002,
income and expenditure account appearing at page 41, chart of income
appearing at page 33, copy of scrutiny assessment orders for the A.Yrs
2001-02, 2002-03 and 2003-04 passed u/s.143(3) allowing the remuneration
to partners as claimed by the assessee submits that the assessee firm
is regularly receiving the amount on account of compensation for use of
shared assets and license fees for the use of name from M/s. Amarchand
A. Shroff & Co. since 01.04.1995 i.e. AY 1996-1997. In all these
years, the said income was offered for tax under the head Income from
Business and Profession. She further submits that in the Profit and Loss
account, the said receipts were shown under the account head Other
Income, as the said income not being received as Professional Fees. She
further submits that the A.O. casually asked the nature of other income
and why it is not shown as income from other sources. In reply to this
query of A.O., a letter was filed saying that the income was not receipt
as Professional Fees, hence it was shown as Other Income but it is
definitely income from Business & Profession and hence chargeable
under the head Income from Business and Profession and so the same could
not be considered as Income from Other Source. The A.O. has wrongly
interpreted the spirit of the letter and taxed Rs.30 lakhs as Income
from Other Source and denied the partners remuneration on the said
amount.
6. The ld. Counsel for the assessee further submits
that though the finding in the previous years does not constitute
re-judicata for the following year, however, this general rule is
subject to the qualification that finding reached in the assessment year
proceeding for earlier year, after due enquiry would not be reviewed in
the subsequent year, if no fresh facts are found in subsequent year.
Therefore, finding of the facts on a similar circumstance will have to
be followed in the later year as a relevant piece of evidence and
therefore it cannot be arbitrarily departed from. In the case of Radhasoami Satsang v CIT
[1992] 193 ITR 321/60 Taxman 248 (SC), the Hon'ble Apex court held that
"strictly speaking, res judicata does not apply to income-tax
proceedings. Again, each assessment year being a unit, what is decided
in one year may not apply in the following year but where a fundamental
aspect permeating through the different assessment years has been found
as a fact one way or the other and parties have allowed that position to
be sustained by not challenging the order, it would not be at all
appropriate to allow the position to be changed in a subsequent year."
According to the ld. counsel for the assessee since the factual position
of the case remains same, the said income has been considered as Income
from Business & Profession, the A.O., without understanding the
nature of the transaction has treated the income as income for Other
Sources, instead of income from Business and Profession.
7. She further submits that both the partners in
their returns have also shown the equal amount of remuneration as
claimed in the return of income of the firm i.e. in the hands of Shri
Shardul A. Shroff Rs. 26,88,290/- and in the hands of Shri Cyril Suresh
Shroff Rs. 26,88,290/- vide chart of income appearing at page 59 and 63
of the assessee's paper book respectively, therefore, there is no loss
to the revenue. She, therefore, submits that the amount of remuneration
claimed by the assessee firm be allowed in full.
8. On the other hand, the ld. DR while relying on
the order of the A.O. and the ld. CIT(A) further submits that since the
assessee itself has admitted that the amount of Rs. 30,00,000/- is not
the professional income as observed by the A.O. at page 2 of the
assessment order and keeping in view that in the earlier assessment
years no such enquiry was made by the A.O. and also keeping in view that
the principle of resjudicata does not apply to the income tax
proceedings, the ld. CIT(A) was fully justified in confirming the order
of the A.O. in treating the license fees of Rs. 30,00,000/- as income
from other sources not eligible for remuneration to partners. Reliance
was also placed on decision of Hon'ble High Court of Bombay in the case
of Piaggio Vehicles (P.) Ltd. v. Dy. CIT [2007] 290 ITR 377 and on the decision of Hon'ble High Court of Delhi in the case of Consolidated Photo & Finvest Ltd. v. Asstt. CIT
[2006] 281 ITR 394/151 Taxman 41 (Delhi). He, therefore, submits that
the order passed by the A.O. and confirmed by the Ld. CIT(A) be upheld.
9. In the rejoinder, the ld. Counsel for the
assessee submits that since the A.O. after application of mind has
consistently accepted the claim of remuneration payable to partners as
claimed by the assessee firm for the assessment years 2001-02, 2002-03,
2003-04 & 2004-05, therefore, the A.O. was not justified in
disallowing the same in the year under consideration. The ld. counsel
for the assessee while distinguishing the decisions relied on by the ld.
DR placed reliance on the decision of Hon'ble High Court of Delhi in
the case of CIT v. Kelvinator of India Ltd. [2002] 256 ITR 1/123 Taxman 433 (FB), wherein it has been observed at page 19 as under:-
"We also cannot accept the submission of Mr. Jolly to
the effect that only because in the assessment order, detailed reasons
have not been recorded an analysis of the materials on the record by
itself may justify the Assessing Officer to initiate a proceeding under
section 147 of the Act. The said submission is fallacious. An order of
assessment can be passed either in terms of sub-section (1) of section
143 or sub-section (3) of section 143. When a regular order of
assessment is passed in terms of the said sub-section (3) of section 143
a presumption can be raised that such an order has been passed on
application of mind. It is well known that a presumption can also be
raised to the effect that in terms of clause (e) of section 114 of the
Indian Evidence Act judicial and official acts have been regularly
performed. If it be held that an order which has been passed purportedly
without application of mind would itself confer jurisdiction upon the
Assessing Officer to reopen the proceeding without anything further, the
same would amount to giving a premium to an authority exercising
quasi-judicial function to take benefit of its own wrong."
She, therefore, submits that the disallowance of partners
remuneration made by the A.O. and sustained by the Ld. CIT(A) be
deleted.
10. We have carefully considered the submissions of
the rival parties and perused the material available on record. We find
that the facts are not in dispute inasmuch as it is also not in dispute
that the assessee firm as per agreements dated 01.04.2002 has shown an
aggregate sum of Rs. 30,00,000/- as "other income" comprising of
compensation for use of shared facilities of Rs. 10,00,000/- and license
fees of Rs. 20,00,000/-. However, while computing the income, the
assessee treated the same as part of "income from business and
profession" in computing the 'book profit' and claimed partners
remuneration allowable as per section 40(b)(v) Rs. 53,76,580/- which has
been equally divided and shown by the partners of the firm namely Shri
Shardul A. Shroff Rs. 26,88,290/- and Shri Cyril Suresh Shroff Rs.
26,88,290/- as salary income from the firm. However, the A.O. while
working out the 'book profit' eligible for partners remuneration has
considered the professional income of Rs. 91,19,055/- and profit on sale
of premises of Rs. 40,35,453/- as 'book profit' and excluded the
dividend and interest income of Rs. 14,04,182/- and other income of Rs.
30,00,000/- in computing the 'book profit' for the purpose of partners
remuneration.
11. The question before us as to whether for the
purpose of computation of allowable remuneration to partners, the 'book
profit' comprises the entire net profit as shown in the profit and loss
account or only profit and gains of business assessed under Chapter IV-D
of the Act.
12. Under clause (v) of section 40(b) read with
Explanation 3, the remuneration allowable to working partners upto Rs.
50,000/- is fully allowable in the hands of the firm. In case the
aggregate payment exceeds the limit of Rs. 50,000/-, certain monetary
limits have been prescribed under section 40(b)(v) in the form of a
percentage of "book-profit". For the purposes of this clause, according
to Explanation 3, the 'book-profit' means the net profit (as shown in
the profit and loss account for the relevant previous year, computed in
the manner laid down in Chapter IVD) as increased by the aggregate
amount of the remuneration paid or payable to all the partners of the
firm if such amount has been deducted while computing the net profit.
The said chapter nowhere provides that net profit should be the only
income from business or profession alone and not from other sources.
Section 29 provides how the income from profits and gains of business or
profession should be computed and this has to be done as provided under
Section 30 to 43D. Thus for the purpose of Section 40(b)(v) read with
Explanation there cannot be separate method of accounting for
ascertaining net profit and/or book-profit. In other words, according to
the said Explanation 'book profit' means the net profit as shown in the
profit and loss account including income from other sources not the
profit computed under the head profit and gains of business or
profession.
13. This view also finds support from the recent decision of Hon'ble Calcutta High Court in the case of Md. Serajuddin & Bros. v. CIT [2012]
210 Taxman 84/24 taxmann.com 46, wherein their lordships while
considering the similar issue under the relevant provisions of section
40(b)(v) of the Act have observed and held as under :-
"The said chapter nowhere provides that method of
accounting for the purpose of ascertaining net profit should be the only
income from business alone and not from other sources. Section 29
provides how the income from profits and gains of business or profession
should be computed and this has to be done as provided under Section 30
to 43D. By virtue of Section 5 of the said Act that total incomes of
any previous years includes all income from whatever source derived.
Thus for the purpose of Section 40(b)(v) read with Explanation there
cannot be separate method of accounting for ascertaining net profit
and/or book-profit. The said section nowhere provides as rightly pointed
by Mr. Khaitan, learned Senior Advocate that the net profit as shown in
the profit and loss account not the profit computed under the head
profit and gains of business or profession.
The decision of the Supreme Court in the case of Apollo Tyres Ltd. v. Commissioner of Income Tax
reported in [2002] 255 ITR 273 (SC) is an appropriate guidance of this
point as to what should be done in order to ascertain the net profit in
case of this nature. At page 280 in the first paragraph of the report
the
Supreme Court observed as follows:-
"Sub-section (1A) of section 115J does not empower the
Assessing Officer to embark upon a fresh inquiry in regard to the
entries made in the books of account of the company. The said
sub-section, as a matter of fact, mandates the company to maintain its
account in accordance with the requirements of the Companies Act which
mandate, according to us, is bodily lifted from the Companies Act into
the Income-tax Act for the limited purpose of making the said account so
maintained as a basis for computing the company's income for levy of
income-tax. Beyond that, we do not think that the said sub-section
empowers the authority under the Income-tax Act to probe into the
accounts accepted by the authorities under the Companies Act. If the
statute mandates that income prepared in accordance with the Companies
Act shall be deemed income for the purpose of section 115J of the Act,
then it should be that income which is acceptable to the authorities
under the Companies Act. There cannot be two incomes one for the purpose
of the Companies Act and another for the purpose of income-tax both
maintained under the same Act. If the Legislature intended the Assessing
Officer to reassess the company's income, then it would have stated in
section 115J that "income of the company as accepted by the Assessing
Officer". In the absence of the same and on the language of section
115J, it will have to held that view taken by the Tribunal is correct
and the High Court has erred in reversing the said view of the
Tribunal."
At page 282 of the said report the Supreme Court has also observed amongst other-
"The fact that it is shown under a different head of
income would not deprive the company of its benefit under section 32AB
so long as it is held that the investment in the units of the UTI by the
assessee-company is in the course of its "eligible business".
Therefore, in our opinion, the dividend income earned by the
assessee-company from its investment in the UTI should be included in
computing the profits of eligible business under section 32AB of the
Act."
Thus it emerges as follows:
Even if the income from other sources is included in
the profit and loss accounts to ascertain the net profit qua book-profit
for computation of the remuneration of the partners the same cannot be
discarded.
In view of the aforesaid discussion as above we,
therefore, allow this appeal and we set aside all the orders passed by
all authorities below. There will be no order as to costs."
14. As regards alternate claim of the assessee that
on the remuneration received by the partners of the firm, the partners
have paid tax, which was not controverted by the Revenue, we are of the
view that it cannot be taxed twice. This view also finds support from
the decision of the Tribunal in Vikas Oil Mill v. ITO [2005] 95 TTJ (JP) 1126, wherein it has been held as under :-
"We are of the view that remuneration paid to working
partners will have to be allowed as per provisions of Section 40(b)(v)
of the IT Act. The Expln. 3 provides the definition for the book profit,
which is already discussed by the CIT(A) in his order at p. 6. Without
repeating, we agree with the order of the CIT(A) in this regard. The
CIT(A) has already discussed a number of case laws to support his order.
So, regarding set off of the carried forward unabsorbed depreciation,
the claim of the assessee is not sustainable. However, about the
alternative prayer of the assessee, we are of the view that the
remuneration will have to be paid to the working partners as per Section
40(b) and it will have to be provided, even in the case of loss, a
minimum of Rs. 50,000. Further, it may be mentioned that the
remuneration received by the partners will have to be taxed either in
the hands of the firm or in the hands of the partners. It cannot be
taxed twice."
15. In Piaggio Vehicles (P.) Ltd. (supra) it has been held as under (head note) :
"Held, dismissing the petition, that depreciation on
intangible assets became available under section 32 of the Act only if
the intangible assets were acquired after April 1, 1998. In other words,
depreciation was not allowable where the intangible assets were
acquired prior to April 1, 1998. Though the goodwill was acquired under
the agreement dated March 30, 1998, in the return of income the
petitioner claimed that the goodwill was effectively acquired on April
1, 1998. During the assessment proceedings, the Assessing Officer by a
letter dated December 5, 2001, had called upon the petitioner to furnish
details of Rs. 4.29 crores shown as goodwill in the books. The
petitioner informed the Assessing Officer that the stamp duty on
transfer of goodwill was paid on April 1, 1998, and that the goodwill
was effectively transferred on June 25, 1998. Accordingly, depreciation
on goodwill was allowed on the footing that it was acquired on or after
April 1, 1998. However, from the agreement dated March 30, 1998, it was
seen that the petitioner had agreed to purchase the B unit as a going
concern on an as is where is basis for Rs. 23 crores plus goodwill
amounting to Rs. 4.30 crores with effect from the specified transfer
date, that is from March 31, 1998. It was recorded in the agreement that
if any of the conditions precedent were not fulfilled, the transfer
date shall be shifted to April 30, 1998. It was not known whether the
transfer date was shifted to April 30, 1998, on account of
non-fulfilment of the conditions precedent set out in the agreement. In
any event, in the tax audit report relating to the financial year April
1, 1998, to March 31, 1999 (assessment year 1999-2000), the goodwill at
Rs. 4.30 crores was shown in the opening block of fixed assets, which
obviously meant that the goodwill was acquired prior to April 1, 1998,
and accordingly in the tax audit report for the assessment year
1999-2000, no depreciation was claimed on the goodwill. Thus, there were
mutual contradictions in the tax audit report and the return of income
filed by the petitioner regarding the date of acquisition of the
goodwill. The argument that the Assessing Officer had taken a conscious
decision to grant depreciation after accepting the contention of the
petitioner that the goodwill was acquired after April 1, 1998, could not
be accepted because, in his letter there was no reference to the
inconsistencies in the tax audit report and the return of income
regarding the date of acquisition of the goodwill. The fact that there
were mutual inconsistencies in the tax audit report and the return of
income which were not noticed by the Assessing Officer at the time of
assessment under section 143(3) of the Act was sufficient reason to
reopen the assessment."
16. In Consolidated Photo and Finvest Ltd. (supra) it has been held as under (head note) :
"Held, dismissing the petition, (i) that the proviso to
section 147 envisages action in the ordinary course within a period of
four years from the end of the relevant assessment year. However, that
limitation does not apply to cases where income chargeable to tax has
escaped assessment on account, inter alia, of the failure of the
assessee to disclose fully and truly all material facts. Production of
the books of account and other documentary evidence relevant for
assessment did not imply a full and true disclosure in the light of
Explanation 1 to section 147. Therefore, the action initiated by the
Assessing Officer did not suffer from any error of jurisdiction to
warrant interference from the court.
(ii) That the order passed by the Assessing
Officer indicated the basis on which income exigible to tax had in his
opinion escaped assessment. The assessment order did not address itself
to the question which the Assessing Officer proposed to examine in the
course of reassessment proceedings. There may be a presumption that the
assessment proceedings had been regularly conducted but there could be
no presumption that even when the order of assessment was silent, all
possible angles and aspects of a controversy had been examined and
determined by the Assessing Officer. The principle that a mere change of
opinion could not be a basis for reopening completed assessments would
be applicable only to situations where the Assessing Officer had applied
his mind and taken a conscious decision on a particular matter in
issue. It would have no application where the order of assessment did
not address itself to the aspect which was the basis for reopening of
the assessment. Therefore, it was inconsequential whether or not the
material necessary for taking a decision was available to the Assessing
Officer either generally or in the form of a reply to the questionnaire
served upon the assessee. What is important was whether the Assessing
Officer had, based on the material available to him taken a view. Since
he had not done so, the reassessment could not be challenged on the
ground that it was based on a change of opinion."
17. There is no quarrel with the principles
enunciated in the aforesaid decisions. However, the case before us is
not under the provision of section 147/148 of the Act but under the
different provisions of the Act. i.e. u/s.40(b)(v) read with Explanation
3, therefore, for the reasons as discussed hereinabove, both the
decisions relied on by the ld. DR are distinguishable and not applicable
to the facts of the present case.
18. For the reasons as discussed above we are of
the view that even if the income from other sources is included in the
profit and loss accounts to ascertain the net profit qua book-profit for
computation of the remuneration of the partners the same cannot be
discarded and the ld. CIT(A) was not justified in upholding the order of
the A.O. in excluding the other income i.e. compensation for use of
shared facilities of Rs. 10,00,000/- and license fees of Rs.20,00,000/-,
aggregating to Rs. 30,00,000/- from the 'book profit' for the purpose
of partners remuneration and accordingly, we direct the A.O. to include
the above sum of Rs. 30,00,000/- in the 'book profit' for computation of
the remuneration of the partners in terms of section 40(b)(v) of the
Act and allow partners remuneration as claimed by the assessee. The
grounds taken by the assessee are, therefore, allowed.
19. Ground no. 4 reads as under :-
"4. Alternate to Ground above the shared asset amount
be assessed under the Income from House Property, as property on which
income is received is owned by Assessee firm."
20. At the time of hearing, the ld. counsel for the
assessee submits that she does not want to press the above ground which
was not objected to by the ld. DR.
21. That being so and in the absence of any
supporting material placed on record by the ld. counsel for the
assessee, the ground taken by the assessee is, therefore, rejected being
not pressed.
22. Ground no. 6 reads as under :-
"The learned CIT(A) erred in confirming levy of interest under-section 220(2)."
23. After hearing the rival parties and perusing
the material available on record, we direct the A.O. to allow
consequential relief to the assessee in this regard. The ground taken by
the assessee is, therefore, allowed.
24. In the result, the appeal filed by the assessee stands allowed.
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