2013 (6) TMI 831

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..... shnan, J. For the assessment year 2006-07, the Commissioner of Income-tax invoked Section 263 of the Income-tax Act, 1961 and issued Annexure G order holding that the manner in which deferred expenditure was quantified and claimed by the assessee is not uniform. The Commissioner was therefore of the view that the Assessing Officer had not called for and examined the issue in its entirety an .....

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..... olding that it is obligatory on the part of the Assessing Officer to record reason for allowing or disallowing the claim of the assessee towards deferred expenditure. The Tribunal also held that since the assessment order did not contain any reason, it did not reflect the application of mind of the Assessing Officer and therefore, there is no infirmity in the order of the Administrative Commission .....

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