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2024 (1) TMI 214 - ITAT MUMBAIDeduction u/s 10A - Allocation of general corporate expenses between the STPI and non STPI units - assessee has maintained separate books of accounts - On the query from the bench on the consistency of methodology adopted by the assessee, the AR submitted that the assessee has been following this system of allocation in the earlier year and subsequent years - AR submitted that the allocation was made to STPI units on the basis of STPI turnover to total turnover and in case of Non STPI units, the basis adopted being domestic turnover to total turnover and the Ld.AR demonstrated the chart on the allocation of expenses - HELD THAT:- Considering the facts, circumstances and evidences filed on consistency adopted by the assessee, the action of the assessing officer is not tenable. Further the revenue could not explain the basis of reallocation of expenses. Whereas the assessee has complied with the accounting principles and policies and has been scientifically allocating the expenses between STPI& Non STPI Units based on the Audited books of Accounts maintained separately. The revenue has accepted the methodology of allocation of expenses adapted by the assessee in the assessment u/sec 143 (3) of the Act for A.Y. 2008-09 to 2012-13. Therefore, the order of the CIT(A) is set aside and direct the assessing officer to accept the methodology adopted by the assessee in allocating the expenses. Decided in favour of assessee.
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