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2021 (3) TMI 619 - AT - Income TaxRevision u/s 263 - Disallowing 70% of the deduction claimed u/s 80IC - HELD THAT:- The schedule of fixed assets we find that as on 01.04.2011, the cost of plant and machinery and the additions made were to the tune of ₹ 1,85,23,460/- which makes the addition more than 50% and justifying that there was substantial expansion as per the relevant provisions of the Act and section 80IC of the Act which fact is also substantiated by the auditor’s report in Form 10CCB wherein the auditors were satisfied that there was substantial expansion as per provisions of the law. Respectfully following the ratio laid down M/S. AARHAM SOFTRONICS [2019 (2) TMI 1285 - SUPREME COURT] we set aside the findings of the ld. CIT(A) and direct the Assessing Officer to allow 100% of the deduction claimed u/s 80IC of the Act. - Decided in favour of assessee.
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