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2014 (4) TMI 1246 - HC - Income TaxAllowability of development expenses incurred on technical knowhow u/s 37 - payment made for providing knowhow to manufacture engines of specific parameters - allowability u/s 35AB - HELD THAT:- Appeal admitted on the following substantial questions of law: (A) Whether on the facts and in the circumstances of the case and in law the Income Tax Appellate Tribunal was justified in allowing development expenses amounting to ₹ 8,93,56,131/which were incurred on technical knowhow under Section 37 of the Income Tax Act even though such expenditure was covered under Section 35AB of the Income Tax Act ? (B) Whether on the facts and in the circumstances of the case and in law the Income Tax Appellate Tribunal was justified in remitting to the file of the Assessing Officer the issue concerning allow ability of development expenses amounting to ₹ 10,69,09,754/being payment made for providing knowhow to manufacture engines of specific parameters even though such expenditure is clearly for technical knowhow and was covered under Section 35AB of the Income Tax Act ?
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