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2015 (9) TMI 1060 - HC - Income TaxAdmission of additional evidence - Held that:- It is seen that before the CIT (A), the Assessee did produce the details on the basis of which the CIT (A) reduced the disallowance proportionate to the expenditure incurred on behalf of the sister concerns both as regards the sales and distribution expenses and administrative expenses. These details have been set out in the order of the CIT (A). The ITAT has also concurred with the finding of the CIT (A). As regards the plea concerning Rule 46 A of the IT Rules, the Court finds that no such point was urged by the Revenue before the ITAT. The Court does not propose to permit the Revenue to urge such question for the first time in this Court. Nothing has been shown to the Court to persuade the Court to conclude that the impugned order of the ITAT is perverse. The findings of both the CIT (A) and the ITAT turned on facts. - Decided against revenue.
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