TMI Blog2018 (2) TMI 1921X X X X Extracts X X X X X X X X Extracts X X X X ..... format is a procedural requirement and as long as during the assessment the same has been complied with, the deduction cannot be disallowed. Several other High Courts have taken a similar view. This Court had referring to the judgments in case of Commissioner of Income-tax v. Gujarat Oil and Allied Industries [ 1992 (9) TMI 67 - GUJARAT HIGH COURT] and in case of Panasonic Energy India Co. Lt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ORAL ORDER (PER : HONOURABLE MR.JUSTICE AKIL KURESHI) 1. Revenue is in appeal against the judgment of the Income Tax Appellate Tribunal dated 09.03.2017 raising following question for our consideration: Whether on the facts and circumstances of the case and in law, the Appellate Tribunal is justified in deleting the disallowance of ₹ 80,48,975/u/ s. 8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9;s contention that such notice was not valid, was not accepted by the Assessing Officer. In response to the notice for reopening, the return of income that the assessee filed, contained the audit accounts under form 10CCB. The Assessing Officer however was of the opinion that since such documents were not filed along with the return, the assessee had breached the requirement of law and the deduct ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... referring to the judgments in case of Commissioner of Income-tax v. Gujarat Oil and Allied Industries reported in 201 ITR 325 and in case of Panasonic Energy India Co. Ltd. v. Assistant Commissioner of Income-tax reported in (2014) 367 ITR 245 (Guj), expressed such a view. 5. Counsel for the Revenue would however rely on some of the observations made in the said judgments in case of Pan ..... X X X X Extracts X X X X X X X X Extracts X X X X
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