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2019 (3) TMI 1168 - BOMBAY HIGH COURTIncome arising out of shipping activities - system of allocation of expenses - Addition on account of adjustment of the ratio for allocation of administrative and other expenses between tonnage and non-tonnage activity - By applying direct income proportionate method, the A.O. allocated the administrative expenses to the extent of 73.06 % to the tonnage tax activity and rest 26.94 % to the non tonnage tax business - Tribunal deleted the addition - HELD THAT:- Tribunal did not approve the stand taken by the A.O. for reallocation of the administrative expenses rejecting the assessee’s treatment which was based on “Annual Operating Charter Hire Income method”, on the ground that in relation to other expenses namely, total operating expenses, interest and finance charges, the A.O. had accepted the method of accounting adopted by the assessee. Similarly, in relation to depreciation also, the A.O. had not make any adjustments. Only in relation to the administrative expenses, the A.O. made the adjustments We are broadly in agreement with the view taken by the Tribunal. No question of law arises. - Decided against revenue
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