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2019 (6) TMI 1252 - AT - Income TaxRevision u/s 263 - Pr. CIT directed to make addition/disallowance in respect of expenditure incurred towards R&D u/s 35(2AB); Capital R&D expense allocated to Sun Pharmaceuticals Industries and re-characterization of remuneration earned from partnership firm (SPI) as royalty income - same disallowances were already subject matter of appeals before Tribunal in earlier years - HELD THAT:- Since issues are covered in assessee’s own cases by the order passed by the Co-ordinate Bench in [2019 (4) TMI 868 - ITAT AHMEDABAD] and [2017 (9) TMI 1804 - ITAT AHMEDABAD] and wherein above disallowances/ additions were deleted. Taking into consideration the order passed by the Co-ordinate Bench in identical issue in assessee’s own cases (supra), we find the disallowance ordered by the Learned PCIT is not sustainable in the eye of law. - assessee’s appeal is allowed
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