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2022 (6) TMI 642 - AT - Income TaxDeduction u/s 10B(7) r.w.s. 80IA(10) - Denial of deduction as assessee is having “more than the ordinary profits” - HELD THAT:- A.O in this case has not brought out why the profits of the assessee will not considered as ordinary profits in the course of business. The A.O has specifically not demonstrated any proof of arrangement for disallowance under the provisions of sec. 10B(7) r.w.s. 80-IA(10) of the Act. The judicial pronouncements clearly makes it mandatory for the Revenue to prove that there is some special arrangement between the assessee and its associated enterprise to earn extra profit and this burden of proof has not been discharged by the Department. In view thereof, we do not find any reason to interfere with the findings of the ld. CIT(A) and the relief provided to the assessee is sustained.
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