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2016 (12) TMI 1348 - AT - Income TaxRevision u/s 263 - Assessee had advanced money to subsidiary company in South Africa in order to establish its products in that market - Held that:- The money advanced by the assessee to the subsidiary company which was incorporated with sole object of marketing the products of the assessee and any advances given to the said subsidiary were out of business consideration and in order to promote the interest of the assessee and thus were given out of commercial consideration and business interest of the assessee. In our opinion, during the year the writing of such advances owing to non recovery was a admissible deduction and therefore, the said advance was rightly claimed as deduction by the assessee company. Therefore, to invoke the provisions of section 263 by exercising the revisionary power by the Commissioner is not justified and cannot be sustained. Accordingly, we set aside the order of Commissioner and restore that of AO. - Decided in favour of assessee.
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