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2022 (4) TMI 227 - AT - Income TaxDeduction u/s 35(1)(iv) for the expenses incurred on engineering and design charges - Disallowance of amount being profit on sale of research and development stating that scientific research was done on behalf of Ford and reimbursement was made by it, and there was no element of profit in it, therefore, the entire amount was required to be offered to tax by the assessee - CIT(A) has dismissed the appeal of the assessee stating that the amount offered for tax was not supported with the relevant document - HELD THAT:- As observed that A.O has also stated that the contention of the assessee that amount has already been offered for tax not supported with relevant documents. We find that in the paper book the assessee has placed various documents and details stating that expenses incurred by the assessee in design and development of the auto components activity has been capitalized as engineering and development cost in the books of account in the past years and claimed deduction u/s 35(1)(iv) as capital expenditure incurred on scientific research. After taking into consideration the submission and material placed in the paper book we are of the considered view that it is appropriate to restore this issue to the fact of the A.O for deciding a de novo after examination/verification of the relevant document and detail filed by the assessee in support of its claim after affording adequate opportunity to the assessee. This ground of appeal of the assessee is allowed for statistical purposes.
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