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2014 (10) TMI 544 - ALLAHABAD HIGH COURTApplicability of section 80IA(10) – Manufacture and sale of Lamination tordials cores and transformers - Assessee was of the view that unit is located in industrially backward area therefore the profits and gains of the unit are eligible for 100% deduction u/s 80IA – Held that:- As decided in CIT Vs. Delhi Press Patra Prakashan Ltd. [2013 (6) TMI 71 - DELHI HIGH COURT] - the assessee was maintaining the separate accounts for each unit as mentioned by the Tribunal, so, the assessee is entitled for the benefit u/s 80 IA and specially when the necessary condition of Section-80 IA (10) has not been fulfilled by the AO to prove that the business between the eligible units and other units are so arranged that the business transaction between them produces more profit to the eligible business - The AO has not given any adverse finding on the basis of books of account produced by the assessee - The AO has also not pointed out any specific item of the eligible unit which is debited by the head office - assessee is entitled for benefit of Section-80 IA – there was no reason to interfere with the order passed by the Tribunal – Decided against revenue.
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