15. We have heard both the parties at length and carefully gone through the materials available on record. In the instant case, the controversy to be resolved is whether assessee was a Local Authority for the year under consideration and as such was eligible for exemption of income u/s. 10(20) of the Act or not. Section 10 of the Act deals with the income which are not to be included in computing total income of previous year
16. The term ‘pending’ means ‘undecided1 i.e something which is not concluded. An action is considered as pending from the time of commencement of the proceedings. Thus, a legal proceeding is pending as soon as commenced and until it is concluded. As per Advanced Law Lexicon, third Edition of 2005, page 3521/3522, following are the definitions of the word ‘pending’:
19. We have considered the rival submissions and perused the material on record. In our considered view inferences drawn by the authorities below are not sustainable in law. The grounds on which the A.O. has added the amount of gift as assessee’s income are summarized by us in para 12. We do not agree that the persons showing income of Rs.80,000 to Rs. 1,50,000 per annum would be persons
19. We have considered the rival submissions and perused the material on record. In our considered view inferences drawn by the authorities below are not sustainable in law. The grounds on which the A.O. has added the amount of gift as assessee’s income are summarized by us in para 12. We do not agree that the persons showing income of Rs.80,000 to Rs. 1,50,000 per annum
7. We have carefully considered the rival submissions and have also perused the materials available on record. The decisions cited at the time of hearing of appeal were duly considered. It is apparent from the record that the assessee company had debited a sum of Rs.2,37,370/ – under the head `travelling expenses’ and claimed the above expenditure as a business expenditure.
(iii) that the signature and every other part of such books of account and other documents which purport to be in the handwriting of any particular person or which may reasonably be assumed to have been signed by, or to be in the handwriting of, any particular person, are in that person’s handwriting, and in the case of a document stamped, executed or attested, that it was duly stamped and executed or attested
5. We have considered the rival submissions and the material on record. In our considered view, the gifts so received by the assessee or his grandsons could not be said to be genuine. The reasons are that in all these cases, the donors are persons of low income group and do not have any capital or asset. There is no evidence on record to show how they build up capital.
