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2023 (6) TMI 227 - HC - Income TaxMethod of apportionment of common expenditure - AO’s computation of income from agricultural activity and income from trading activity was modified - Tribunal justification in holding that common expenditure for own production and sale of seeds and trading in other seeds can be apportioned between both on the basis of Cost of Goods Sold (CoGS) as against the turnover of each for arriving at profits - HELD THAT:- According to the Tribunal, view taken by CIT(A) was a reasonable one and cannot be termed as perverse. More so, in view of the seasonal nature of the business carried out by the assessee and the short shelf life of the seeds, Tribunal has held that it is imperative for the assessee to take into account the quantity of unsold seeds at the end of the year and the need to re-validate their further utility and to take them into stock for the next season. Therefore, it cannot be said that the provision for sales returns is unascertained or unreasonable. Affirming the findings written by CIT(A), Tribunal dismissed the appeal of the revenue.No error or infirmity in the view taken by the Tribunal. No substantial question of law.
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