S.MANIKUMAR, D.KRISHNA KUMAR
Gerard Perira – Appellant
Versus
Income-Tax Officer, Range XV(1), Chennai – Respondent
S. MANIKUMAR, J.
Tax Case Appeal is directed against the order made in I.T.A. No. 3094/Mds/2004, dated 21.09.2006, on the file of the Income Tax Appellate Tribunal, 'A' Bench, Chennai, for the assessment year 1999-2000.
2. Short facts leading to the appeal are that the appellant is engaged in the manufacture and export of fabrics. For the assessment year 1999-2000, the appellant has filed return of income on 24.12.1999, wherein, he had adjusted the gross total income of Rs. 25,51,237/-, against deductions of Rs. 26,01,894/- and Rs. 12,000/-, under Sections 80HHC and 80L of the Income Tax Act, 1961, respectively. The claim of Rs. 26,01,894/-, also included deduction, under Section 80HHC of the Act, in respect of interest income of Rs. 20,58,049/-, which the appellant treated, as business income.
3. The assessing officer issued notice, under Section 148 of the Act, followed by notices, under Sections 142(1) and 143(2) of the Act and after considering the material on record, and the submissions of the appellant's representative, passed an order, dated 13.01.2004, under Section 143(3) of the Act, determining the taxable income at Rs.21,78,049/- and allowed deduction, under Section
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