TMI Blog2015 (8) TMI 421X X X X Extracts X X X X X X X X Extracts X X X X ..... cultural and non-agricultural income/ receipts has been used even while working out the apportionment of expenditure under that head. The previous history not in dispute shows that since 1996-97, the said method is being adopted. It is not in dispute that in the return filed by the assessee (State Government Corporation), the receipts were, accordingly, mentioned and the expenditure for those rece ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that is not the position here.There was no scope for intervention under section 263 of the Act - Decided in favour of assessee. - Income Tax Appeal No. 2 of 2010 - - - Dated:- 6-4-2015 - B.P. DHARMADHIKARI S.B. SHUKRE, JJ. Shri. Parchure, Advocate, for the appellant Shri. Thakar, Advocate, for the respondent JUDGMENT Heard Shri Parchure, learned counsel for the appellant an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e matter. According to the learned counsel, percentage of apportionment between two expenditures was different in every year, thereby necessitating application of mind to relevant facts and as the assessment order does not disclose this approach, it is vitiated. He further submits that the Commissioner of Income-tax has placed back the matter for fresh consideration and, therefore, no prejudice is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e have perused the papers. The facts show that the proportion of agricultural and non-agricultural income/ receipts has been used even while working out the apportionment of expenditure under that head. The previous history not in dispute shows that since 1996-97, the said method is being adopted. It is not in dispute that in the return filed by the assessee (State Government Corporation), the rec ..... X X X X Extracts X X X X X X X X Extracts X X X X
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