PR.COMMISSIONER OF INCOME TAX Vs. M/SHARYANA STATE INDUSTRIAL AND INFRASTRUCTURE DEVELOPMENT CORPORATION LIMITED

JUDGEMENT

(1.) This order shall dispose of ITA Nos. 147 to 149, 155, 161, 175, 179, 180 and 223 of 2018, as according to the learned counsel for the appellantrevenue, the issue involved in all these appeals is identical. However, the facts are being extracted from ITA No.147 of 2018.

(2.) ITA No.147 of 2018 has been filed by the appellant revenue under Sec. 260A of the Income Tax Act, 1961 (in short, "the Act") against the order dtd. 16/11/2017 passed by the Income Tax Appellate Tribunal, Division Bench 'A', Chandigarh in ITA No.184/CHD/2010 for the assessment year 2005-06. Following substantial questions of law have been claimed in ITA Nos.147, 148, 175 and 179 of 2018:-

(3.) A few facts relevant for the decision of the controversy involved as narrated in ITA No.147 of 2018 may be noticed. The assessee corporation was set up with the objective of development of industries in the State of Haryana. It is primarily engaged in the financing activities and developing the industrial estates. The assessee for the assessment year in question i.e. 2005-06 filed its return of income on 29/10/2005 by declaring an income of Rs.12,93,53,616.00. The assessee maintained its accounts on cash system of accounting. Notice under Sec. 143(2) of the Act was issued and served on the assessee on 31/1/2006. The assessee participated in the proceedings through its representative and furnished books of account etc. After considering the entire material on record, the Assessing Officer framed the assessment vide order dtd. 24/12/2007, Annexure A.1, making the following additions:-