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2013 (7) TMI 324

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..... -2013 - Sanjiv Khanna And Sanjeev Sachdeva,JJ. For the Appellant : Ms. Suruchi Aggarwal, sr. standing counsel. For the Respondent Through Mr.Satyen Sethi and Mr. Arta Tarana Panda, Advocates. JUDGMENT Sanjiv Khanna, J. (Oral) This appeal by the Revenue, which pertains to the assessment year 1999-2000, raises three issues. The first issue relates to deletion of addition of R .....

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..... sue had been decided in favour of the assessee in the earlier years. The said finding recorded by the tribunal is incorrect as no addition to book profits for this reason was made under Section 115 JA in the earlier assessment years. However, we do not think that the aforesaid adjustment could be made while computing book profit under Section 115 JA. We have already upheld the order of the tribuna .....

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..... CIT (Appeals) deleted the said disallowance, observing that it was a revenue expense and the expenditure was incurred on training of employees after the business was setup and production had commenced. The said finding has been upheld by the tribunal. It is not the case of the Revenue that the business had not commenced in the assessment year 1998-99. The findings of the tribunal are correct. 4 .....

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