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2023 (6) TMI 609 - AT - Income TaxTP adjustment - claim of working capital adjustment - HELD THAT:- Assessee had never raised any argument seeking working capital adjustment. It is for the first time before the Tribunal that the assessee has raised a plea for grant of working capital adjustment. For adjudicating additional ground no fresh document is required to be adduced. Therefore, we admit additional ground of appeal. Since, the relief sought has been raised for the first time before the Tribunal, we deem it appropriate to restore the additional to the file of Assessing Officer for his consideration. The Assessing Officer is directed to consider the claim of working capital adjustment made by the assessee in the additional ground of appeal. Disallowance of sales promotion expenditure u/s. 40(a)(ia) - HELD THAT:- We find that similar ground was raised by the assessee in Assessment Year 2016-17[2023 (2) TMI 190 - ITAT MUMBAI] where held as in view of this second proviso, we direct the ld. AO to make factual verification as to whether the recipients had duly disclosed the subject mentioned receipts in their returns of income. The assessee is directed to furnish the necessary details in this regard in the prescribed form. Assessee appeal is allowed for statistical purpose
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