TMI Blog2019 (6) TMI 1262X X X X Extracts X X X X X X X X Extracts X X X X ..... onent (s) : None ORAL ORDER (PER : HONOURABLE MR.JUSTICE J.B.PARDIWALA) 1. This Tax Appeal under Section 260-A of the Income Tax Act, 1961 (for short "the Act, 1961") is at the instance of the Revenue and is directed against the order passed by the Appellate Tribunal, "C" Bench, Ahmedabad in ITA No.168/Ahd/2017 for the Assessment Year 2012-13. 2. The Revenue has proposed the following subst ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... attention on the allowability of the expenditure as business expenditure. With respect to these findings, we have no hesitation in concurring. Nevertheless, since the authorities below have not in detail examined the nature of the expenditure, we have taken note of the details of the programme and the nature of activities undertaken by GCMMF through such programme. We may note that even the Asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... accination at mass scale, provide balanced cattle feed etc. 10. It can thus be seen that the expenditure was general in nature and aimed at improving the practices for better fertility amongst milk animals by addressing the issues which caused infertility. The expenditure therefore was for the purpose of its business and would not be co-relatable to any tangible returns which can be expected ou ..... X X X X Extracts X X X X X X X X Extracts X X X X
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