TMI Blog2003 (12) TMI 10X X X X Extracts X X X X X X X X Extracts X X X X ..... - Instead, there was a presumption made that any technology about new flavours and essence will automatically be utilized in Chittoor unit also without examining as to whether the research and development actually carried out at Madras was of use for the unit at Chittoor, as the assessee has other manufacturing units besides the one at Chittoor. It is only on such presumption, allocation of the r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2,889 as expenditure on research and development pertaining to Chittoor unit. The assessee's appeal and further appeal to the Tribunal having proved unsuccessful, the assessee is now before us. Counsel for the assessee submitted that the amount so included does not pertain to the Chittoor unit, in which unit there is no research and development activity undertaken and carried out. Learned counse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing Officer allocated a sum of Rs. 54,92,889 as expenses for the benefit of the Chittoor unit as a consequence of which the deductions under sections 80HH and 80-I of the Income-tax Act got reduced and the burden of taxation becomes heavier for the assessee. Learned counsel for the assessee submitted that there was no research and development expenses at Chittoor unit, and that research and dev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the research and development actually carried out at Madras was of use for the unit at Chittoor, as the assessee has other manufacturing units besides the one at Chittoor. It is only on such presumption, allocation of the research and development expenses to Chittoor unit was held by the Tribunal to be justified. For the purpose of determining as to whether at all there was research and developm ..... X X X X Extracts X X X X X X X X Extracts X X X X
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