Deletion of addition based on previous year judgment without recording findings of the issue not allowed

Advertisement Brief of the Case Calcutta High Court held In the case of CIT vs. Williamson Magor & Co. Ltd. that ITAT decision with regard to questions (a), (b), (c) & (f) is based on earlier high court decisions, so no fresh consideration is required. The question nos.(d) and (e) are questions on facts. The only point in these questions was that the payment was in connection with services rendered and billed for on 28th February, 1997 and therefore, the expenditure could not be allowed in a subsequent year but ITAT held that an appeal relating to the year to which the expenditure p...