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2012 (8) TMI 734 - AT - Income TaxAdjustment to valuation determined by DVO under reference made u/s 142A - Revenue contesting grant of deduction @ 15% on account of rate difference between the CPWD rates and the rates existing in Khothagudem and Khammam and also on account of self supervision @ 10% - assessee firm, engaged in the business of running a hotel at Kothagudem, Khammam, constructed six storied hotel building - Held that:- There is no dispute in the present case with regard to existence of difference in the CPWD rates adopted by the DVO and the local rates prevailing in Kothagudem/Khammam, hence, assessee is entitled for deduction at the rate of 15%. Percentage of deduction on this account depends on the facts of each case and the steel rate differences. Deduction towards self supervision at the rate of 10% - Revenue contending deduction @ 7.5% - Held that:- Considering the size of the town and the asset under consideration( six storeyed hotel building), it is held that assessee was in an advantageous position to bargain the rates to the maximum benefit of the assessee, in which case, higher deduction is justified - Decided against Revenue
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