TMI Blog2015 (6) TMI 324X X X X Extracts X X X X X X X X Extracts X X X X ..... id submission of the learned Counsel for the appellants, as by accepting the return filed by the assessee in which the requisite details had been given, it was not necessary for the Assessing Officer to give detailed reasons, although it could be said that had such reasons been given, it may have been better. However, the order cannot be said to be erroneous in sofar as it is prejudicial to the in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as to whether after the amendment brought in sub-section 4 of Section 10A of the Income Tax Act, 1961 with effect from 01.04.2001, while computing the deduction the total turnover of the undertaking is to be considered or the total turnover of the business of the Company is to be considered ? 3. The brief facts of this case are that on the basis of the amended provision of subsection (4) of Se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal was correct in setting aside the order passed u/s.263 of the Act, where the commissioner had held that the computation of deduction u/s.10A of the Act when computing total income should be in respect of both STP units as well as non-STP units i.e., in respect of the entire company has been contrary to the provision and without jurisdiction? 4. Learned Counsel for the appellants has not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... requisite details had been given, it was not necessary for the Assessing Officer to give detailed reasons, although it could be said that had such reasons been given, it may have been better. However, the order cannot be said to be erroneous in sofar as it is prejudicial to the interests of the revenue or taken up for revision under Section 263 of the Act, merely because no reasons had been given ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
