IN THE HIGH COURT OF DELHI AT NEW DELHI
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ITA 981/2006
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M/S CHEMICAL CONSTRUCTION INTE ..... Appellant
Through Mr. D.N. Sawhney and
Mr. M.D. Rastogi with
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Mr. K.M Ahuja, Advocates.
versus
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COMMISSIONER OF INCOME TAX I ..... Respondent
Through Mr. J.R. Goel, Advocate.
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CORAM:
HON'BLE MR. JUSTICE MADAN B. LOKUR
HON'BLE MR. JUSTICE V. B. GUPTA
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O R D E R
23.01.2007
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Admit.
After hearing learned counsel for the parties we are of the view that
following substantial questions arise for our consideration:-
?(i) Whether the Income Tax Appellate Tribunal is correct in law to hold
that the supply of drawing and
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ITA No. 981/2006 Page 1 of 3
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design and engineering know-how in relation to turnkey projects are independent
contracts, have no relation with supply, erection and commissioning of plant and
receipt thereof will be assessed in the year other than the year in which
projects were completed?
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(ii) Whether the Income Tax Appellate Tribunal is correct in law to hold that
the amounts of Rs. 50 lakhs and Rs.65 lakhs received from M/s Goetze India Ltd.
and M/s Rama Phosphates Ltd. under independent contracts were to be always
considered separately not connected with the supply and commissioning of Soya
Extraction Plant?
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(iii) Whether the Income Tax Appellate Tribunal is correct in law to sustain
the disallowance of expenditure of Rs. 7,87,512/- in the absence of original in
spite of production of photocopies of the vouchers available and
the fact that payments were made by account payee cheques?
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(iv) Whether the Income Tax Appellate Tribunal is correct in law to
sustain the disallowance of Rs. 5,17,313/- out of plant erection expenses, petty
in nature incurred at site, in the absence of evidence, particularly since
similar payments have been allowed by the Income Tax Appellate Tribunal in the
Assessment Years 1994-1995 and 1995-1996??
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Paper books be filed in accordance with the High Court Rules.
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MADAN B. LOKUR, J
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V. B. GUPTA, J
JANUARY 23, 2007
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ITA No. 981/2006 Page 3 of 3