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TMI Blog2018 (10) TMI 867X X X X Extracts X X X X X X X X Extracts X X X X ..... in, Sr. Standing Counsel. O R D E R C.M. No.38152/2018 Exemption allowed, subject to all just exceptions. ITA 1017/2018 This appeal by, Deepak Pahwa ('appellant-assessee' for short) arises from the order dated 14th May, 2018 of the Income Tax Appellant Tribunal ('Tribunal' for short), and relates to the Assessment Year 2004-05. 2. Contention of the appellant-assessee t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ned order passed by the Tribunal dated 14th May, 2018 reads as under:- "8. The Ld CIT(A) had also considered the manpower cost in addition to the above expenditure noted in the table. In the above table, the assessee has allocated the expenditure incurred at the Head officer and its branches which has been doubted by the lower authorities . The Assessee has created the Branch offices for business ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ost incurred at the head office and Branch office and staff welfare cost has already been considered in the above table. Needless to say, the Assessee shall be given reasonable (sic) opportunity of being heard." 5. The Tribunal has not directed that branch office expenditure should be taken into consideration, for the case of the appellant-assessee was that the branch offices were for business pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... set aside the said additions and made an order of remand. 8. We would clarify that the Assessing Officer while examining the question of disallowance under Section 14A would take into consideration all contentions and pleas of the appellant-assessee. Both the Assessing Officer and the appellant-assessee are bound by the ratio in Godrej and Boyce Manufacturing Company Ltd. (Supra) and Maxopp Inve ..... X X X X Extracts X X X X X X X X Extracts X X X X
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