TMI Blog2011 (6) TMI 69X X X X Extracts X X X X X X X X Extracts X X X X ..... accordance with its main objects contained in memorandum of Articles of Association of the company - assessee was appointed as Nodal Agency for two projects by the Government as well as Semi-Government organizations - In furtherance of such responsibilities, assessee had also undertaken certain tasks - Expenditure was borne by the parent agency - find that CIT(Appeals) as well as tribunal both hav ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... riginal objects, then it is sufficient to conclude that business has commenced? (C) Whether the Appellate Tribunal is correct in holding that the assessee has already commenced its business and allowing the business expenses against interest income? Central issue is whether during the assessment year in question, assessee had commenced its business activities. The Assessing Officer was of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the public. During the year in question assessee incurred expenditure of Rs.24,70,524/- and claimed it as business expenditure. Assessing Officer however, disallowed the claim holding that assessee had not yet commenced business activities during the year in question. The tribunal however, was of the opinion that the assessee company had undertaken activities in earlier year in accordan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... We find that CIT(Appeals) as well as tribunal both have taken into account relevant evidence and come to the conclusion that the respondent assessee had in fact started its activities at-least during the year in question. Notably assessee was appointed as Nodal Agency for two projects by the Government as well as Semi-Government organizations. In furtherance of such responsibilities, assessee h ..... X X X X Extracts X X X X X X X X Extracts X X X X
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