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2016 (4) TMI 951 - HC - Income TaxRevision u/s 263 - allocation of administrative expenses - Held that:- No finding had been given by the CIT under Section 263 of the Act as to how the debit of administrative expenses made in the profit and loss account of Unit No.1 prima facie resulted in excess profit in Unit No.II and how any of such expenses were relatable to Unit No.II. The CIT merely set aside the issue without finding any error in the assessment made by the Assessing Officer. The two conditions for invoking the provisions of Section 263 of the Act were not fulfilled i.e. firstly how debit of administrative expenses in the profit and loss account of Unit No.1 rendered the assessment as erroneous and secondly how the same was prejudicial to the interest of the revenue. - Decided in favour of assessee.
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