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2023 (9) TMI 887 - ITAT DELHIRectification u/s 154 - Justification of expenditure w.r.t. head office expenses u/s 37(1) vis-a-vis the receipts of the assessee - HELD THAT:- On perusal of the order of the Ld. CIT(A), we find that he has given a clear finding that the sum represents the allowable expense of the assessee and not its alleged ‘undeclared income’. This finding of the Ld. CIT(A) remained uncontroverted before us. We concur with the findings of the Ld. CIT(A). Further, the issue of allowability of the said expense was the subject matter of consideration in quantum appeal and therefore the Ld. CIT(A) has rightly not considered it in rectificatory proceeding. For the reasons set out above we do not find any substance in the appeal of the Revenue which we reject.
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