2014 (3) TMI 1208

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..... hri Anirudh Rai, IRS, CIT ORDER PER Dr. O.K. NARAYANAN, VICE-PRESIDENT These two appeals are filed by the assessee. The relevant assessment years are 2006-07 and 2007-08. The appeals are directed against the order of the Commissioner of Income-tax (Appeals)-I at Coimbatore, both dated 29-06-2010. The appeals arise out of the assessment completed under section 143(3) of the Income-tax Act, 1961. .....

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..... tax (Appeals) has erred in sustaining the disallowance of expenses quantified in applying Rule 8D read with sec.14A of the Act. 5. The issue of deduction u/s.80JJAA, has been considered in detail by the assessing authority as well as by the Commissioner of Income-tax(Appeals). The Commissioner of Income-tax(Appeals) has held that the claim of deduction under sec.80JJAA in respect of regular work .....

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..... ar workmen employed in the preceding year. Accordingly, we agree with the finding of the Commissioner of Income-tax (Appeals) that the claim of the assessee for deduction under sec.80JJAA in respect of regular workmen employed in the earlier years relevant to the assessment year is not sustainable in law. As this is the main issue raised by the assessee, it is not necessary to deal with the arithm .....

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