Principle of law apparent is real onus is on the person who alleges that apparent is not real

Learned AR contended that the assessee incurred labour cost in executing works contracts (pertaining to road strengthening and preventive maintenance and repairs) awarded by Effluent Channel Project (ECPL) for GIDC through competitive and totally transparent bidding process. These are labour oriented work. It was pointed out that similar work has been carried by the assessee from the assessment years 1999-2000 to assessment year 2004-05 and always the assessee has incurred the labour charges were never disallowed except in the impugned assessment year.

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